I
   Note: EPA no longer updates this information,
   but it may be useful as a reference or resource. ;
      & EPA
               United Stales
               Environmental Protection
               Agency
            Office of Air Quality
            Planning and Standards
            Research Triangle Park, NC 27711
EPA-452/R-92-010
November 1992
               ATT
GUIDELINES FOR ESTIMATING
AND APPLYING RULE
EFFECTIVENESS  FOR OZONE/CO
STATE IMPLEMENTATION PLAN
BASE YEAR INVENTORIES

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GUIDELINES FOR ESTIMATING AND APPLYING RULE EFFECTIVENESS FOR
              OZONE/CO  STATE  IMPLEMENTATION FLAN
                    BASE YEAR INVENTORIES
               Ozone  and Carbon Monoxide Branch
               Air Quality Management Division
        Office of Air Quality Planning and Standards
            U.S. Environmental Protection Agency
        Research Triangle  Park, North Carolina 27711

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                             ADDENDUM
After preparation of this document, EPA decided to recommend
additional flexibility in accounting for rule effectiveness  (RE)
in the development of base year emission inventories.  This
addendum provides guidance regarding that flexibility.

METHODS FOR ACCOUNTING FOR RULE EFFECTIVENESS FOR VOLATILE
ORGANIC COMPOUND  (VOC) SOURCES

A State or local agency that prepares VOC emission inventories
may account for rule and control effectiveness by methods other
than those specified in this document.  Deviations from methods
in document must meet the following criteria, as well as criteria
specified in "Documentation and Concurrence," below:

     —In evaluating rule effectiveness under a method that
     deviates from the guideline, the State should consider:
                                                  *              _
          —The overall capture and control efficiency generally
          available from the kind of capture and control
          equipment being assessed;

          —Any stack test/performance evaluation that was
          performed on the capture and control equipment;

          —The rated capture and control efficiency (from
          manufacturer's specifications or literature);

          — The kinds of activities that affect the
          determination of day-to-day performance of the capture
          and control equipment that are listed in the
          questionnaires that are contained in the guideline
          document (e.g., ease of determining compliance, type of
          control equipment, frequency and quality of
          inspections, level of training of inspectors).

     —The State or local agency should provide a way of
     determining which sources have applied control to avoid
     having planners "recontrol" already controlled sources.

METHODS FOR ACCOUNTING FOR RULE EFFECTIVENESS FOR SOURCES OF
OXIDES OF NITROGEN AND CARBON MONOXIDE

     Rule effectiveness must be considered for sources of oxides
of nitrogen and carbon monoxide where such sources are covered by
rules or regulations in the State implementation plan (SIP).  If
a State or local agency does not use either the questionnaire
method or the Stationary Source Compliance Division (SSCD)
protocol, that agency should develop its own method for assessing
RE and should not rely solely on the 80 percent default value.
                                11

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In evaluating rule effectiveness under such a method, the State
should consider the kinds of activities that are listed in the
questionnaires that are contained in the guideline document
(e.g., ease of determining compliance, type of control equipment,
frequency and quality of inspections, competence of inspectors).
Methods for accounting for rule effectiveness different from the
methods in the document must also meet the criteria specified in
"Documentation and Concurrence," below.

RARE CATASTROPHIC OR ACCIDENTAL RELEASES

     Rare catastrophic or accidental releases may be inventoried
in a manner deemed appropriate by the State or local agency;
these releases do not necessarily need to be reflected in a rule
effectiveness assessment, unless there is a pattern of re-
occurrence.  The methods developed must meet the criteria
specified in "Documentation and Concurrence," below.

DOCUMENTATION AND CONCURRENCE
                                                  *              -^
     The above paragraphs describe cases where methods that
deviate from the methods in this document may be employed.  In
developing and using such a method,  the following general
criteria must be met:

     —The Regional Office, in consultation with the EPA Office
     of Air Quality Planning and Standards, must concur on the
     method.                  '

     —Documentation must be available at the State or local
     agency for inspection by EPA; documentation does not have to
     be submitted with emission inventory.
                               111

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                        TABLE OF CONTENTS
Section
Page
Addendum	ii
List of Tables	vi
List of Figures	vi

1   INTRODUCTION  	 1
    1.1 Background	2
    1.2 Meaning of Rule Effectiveness	3
    1.3 Rule Effectiveness for Base Year Inventories	4
    1.4 Factors Affecting Rule Effectiveness  	 5
    1.5 Calculating and Applying Rule Effectiveness 	 5
    1. 6 References	8

2   PROCEDURES FOR ESTIMATING CATEGORY-SPECIFIC RE  ...... 9
    2.1 Determining Sources for Application of Rule
        Effectiveness 	 9
        2.1.1   Excepted Sources  	 9
        2.1.2   Direct Determination of Emissions 	  11
            2.1.2.1 Criteria for Direct Determination
                    Emissions	12
            2.1.2.2 Example of Direct Determination 	  12
            2.1.2.3 Major Classes of Emissions
                    Estimation Techniques 	  13
            2.1.2.4 Documenting Direct Determination  ....  15
    2.2 Overview of Applicable Approaches for
        Determining RE	16
    2.3 Default Value Approach  	  16
    2.4 Questionnaire Approach  	  18
        2.4.1   Level of Effort	18
        2.4.2   Procedure	19
            2.4.2.1 Identifying Personnel to Perform
                    the Evaluation	19
            2.4.2.2 Preliminary Screening of Sources  ....  19
            2.4.2.3 Choosing Sources to Evaluate  	  20
            2.4.2.4 Sources with Control Efficiencies
                    Greater Than 95 Percent	21
            2.4.2.5 Answering the Questionnaires  	  22
            2.4.2.6 Determination of Rule Effectiveness
                    Values	22
    2.5 SSCD Study Approach	23
        2.5.1   Purpose of the Study	23
        2.5.2   Summary of the SS.CD Study
                Approach Procedures 	  24
        2.5.3   Calculating RE from an SSCD Study   	25
    2.6 Using Results from SSCD Studies,
        Questionnaires and the Default	27
                                IV

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                  TABLE OF CONTENTS  (continued)
Section
Page
3   APPLICATION OF RULE EFFECTIVENESS IN
    BASE YEAR INVENTORIES	30
    3.1 Introduction	30
    3.2 Calculating Rule-Affected Emissions  	   30
        3.2.1   Control Efficiency   	   31
        3.2.2   AIRS Coding	 .  .   33
    3.3 Documenting Rule Effectiveness for the
        SIP Submittal	34
    3.4 References	34

4   EXAMPLE CALCULATIONS   .....'	36
    4.1 Point Sources	36
        4.1.1   Bulk Terminals  (Loading Racks)   	   36
        4.1.2   Beverage Can Coating	v	   37
        4.1.3   Paper Coating Facility  .....*	~40
        4.1.4   Metal Furniture Coating 	   40
        4.1.5   Automobile Assembly Plant 	   41
        4.1.6   Large Appliance Coating 	   42
        4.1.7   Large Petroleum Dry Cleaner  	   43
        4.1.8   Graphic Arts	43
    4.2 Area Sources	45
        4.2.1   Stage I (Area Source Category)   	   45
        4.2.2   Architectural Coating
                (Area Source Category)  	   46



APPENDIX A: RULE EFFECTIVENESS EVALUATION
            FORM-POINT SOURCES  	 A-l

APPENDIX B: RULE EFFECTIVENESS QUESTIONNAIRE-AREA
            SOURCE CATEGORIES 	 B-l

APPENDIX C: DIRECT DETERMINATION EXAMPLE  	 C-l

APPENDIX D: DETERMINING SAMPLE SIZE  	 D-l

APPENDIX E: DEFAULT CONTROL ASSUMPTIONS FOR
            CTG CATEGORIES	E-l

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                          LIST OF TABLES


Number                                                       Page

1-1 Factors Influencing Rule Effectiveness  	 6

1-2 Applying RE in Base Year SIP Inventories	7

2-1 Source Categories Covered by EPA Control
    Techniques Guidelines  (CTGs)  	  10

2-2 Direct Determination Scenarios  .  .  .	12

2-3 Emission Estimation Methods  .	14

2-4 Documenting Direct Determination for Surface Coating  .   .  17

2-5 Example of Weighted RE Value Using Questionnaire  ....  24

2-6 Combining SSCD Study and Questionnaire Approaches ....  29

3-1 Default Petroleum Storage Tank Control Efficiencies ...  32

3-2 Coding RE in Electronic Inventory Submittals  	  34

D-l Sensitivity Analysis of Sample Size:
    Confidence Level = 90%	D-5

D-2 Sensitivity Analysis of Sample Size:
    Confidence Level = 95%	D-6

D-3 Sensitivity Analysis of Sample Size:
    Confidence Level = 99%	D-7

E-l Typical VOC Reduction per Facility for CTG Categories
    Based on CTG Documents	E-3
                         LIST OF FIGURES


Kumbar                                                       Page

2-1 Comparison of the Questionnaire and SSCD Study	28
                                VI

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                            SECTION 1
                          INTRODUCTION
    Emission inventories are assembled with the intent to provide
the most accurate, representative emissions estimates available.
The 1990 Clean Air Act Amendments (CAAA)  require base year annual
and daily actual emission inventories to be gathered as part of
the State implementation plan (SIP)  for areas not in attainment
for the current ozone and/or carbon monoxide (CO)  national
ambient air quality standards (NAAQS).   These estimates are used
to support inventory projections, ambient modeling applications,
attainment strategy (regulatory) development and subsequent
(periodic) inventories.

    Prior to the post-1987 SIP requirements, SIP inventories and
their applications assumed that regulatory programs for
stationary sources were being and would continue to be
implemented with full effectiveness, achieving all of the
reported, required or intended emission reductions, and
maintaining that level over time.  However, experience during the
decade of the 1980s has shown these regulatory programs to be
less than 100 percent effective in achieving the necessary
emissions reductions in most areas of the country.  This means
that SIP's before 1987 typically have understated actual
emissions in both the baseline and projected inventories,
resulting in lower emission reduction targets than were actually
necessary to attain the NAAQS.

    To avoid these miscalculations and more accurately estimate
actual emissions, consideration shall be made for "rule
effectiveness."  This document provides guidelines for
calculating and applying rule effectiveness in SIP base year
inventories.  The concepts and procedures discussed herein
currently apply to ozone nonattainment  area inventories, but will
be applicable to SIP inventories for other pollutants as the need
arises.  This guidance focuses on developing estimates of rule
effectiveness (RE) for the inventory that are used to obtain more
realistic emission estimates for source categories.

    This guidance describes the procedures developed by the
Office of Air Quality Planning and Standards (OAQPS)  to estimate
the effectiveness of existing regulatory programs to achieve
emissions control for stationary sources.  One approach is the
detailed study protocol developed by the Environmental Protection
Agency (EPA) Stationary Source Compliance Division (SSCD)
involving on-site inspection and testing on a single source
category by source category basis.  The second approach,
developed by the Air Quality Management Division (AQMD), involves
answering generic questionnaires using  available file information
for specific sources and extrapolating  the results to other
sources in the same source categories.   The third option is to
use the 80 percent default for estimating RE.  The results-of

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these approaches  are to be used to estimate RE for the base year
emission  inventories being prepared in response to the 1990 CAAA
calls for ozone and CO SIP's.

    The document  is divided into four main sections.   The
remainder of  Section 1 discusses the definitions and roles of
various types of  effectiveness  measures that have historically
been referred to  as "rule" effectiveness and introduces the
concepts  covered  in this guidance.  Section 2 describes the
procedures to be  used in estimating category-specific RE values
for States that choose not to use the 80 percent default.
Section 3 contains  instructions on how to apply RE to sources in
the base  year inventories,  including a discussion of  direct
determination of  emissions.  Section 4 provides RE examples to
aid in the calculation of emissions for base year inventories.
Appendices A  and  B  contain the  point and area source  RE
questionnaires, respectively; Appendix C illustrates  direct
determination and Appendix D provides statistical guidelines for
sample selection  for the point  source questionnaire.   Appendix E
presents  typical  VOC emissions  reductions for Control Techniques
Guideline categories.

1.1 BACKGROUND

    On November 24,  1987,  EPA proposed the post-1987  ozone/CO
policy.1  A key component of this policy  was the proposal that
States account for  the actual effectiveness of both present and
future regulatory programs.  This measure was  termed  "rule"
effectiveness and represented the actual degree of source
compliance.   For  stationary  sources,  EPA proposed that a baseline
assumption of 80  percent RE  should be applied to all  regulated
source categories in the inventory until a local category-
specific  evaluation could be completed to ascertain the actual
category-specific effectiveness.   (This 80 percent default value
was initially based on a survey of several states that estimated
the actual effectiveness of  their emissions rules.)

    EPA received  numerous comments regarding the RE requirements
proposed  in that  policy.   None  of the commenters challenged the
concept of applying RE in-the inventories or of improving the RE
of particularly troublesome  categories.   Many  commenters,
however,  suggested  that EPA  provide an alternative to the across-
the-board 80  percent presumption.   The general theme  contained in
these comments suggested that EPA should allow State  and local
agencies  flexibility in making  RE estimates so that regulatory
programs  showing  good compliance  rates for certain source
categories could  receive higher credit than those showing lower
compliance rates.1
lrrhe issue  of the creditability of  RE improvements towards meeting reduction
goals is not discussed in this document.  Creditability will be included in a
more general discussion of rule effectiveness in forthcoming guidance.

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    EPA provided guidance to the States in preparing the new siPs
pursuant to Title I of the CAAA through the Federal Register
(General Preamble for Title I Implementation, April 16, 1992) .
EPA policy requires that base year stationary source inventories
of volatile organic compounds (VOCs), nitrogen oxides  (NOJ  and
carbon monoxide  (CO) be adjusted for RE, using either the 80
percent default value or the results from one of the procedures
described herein.

1.2 MEANING OF RULE EFFECTIVENESS

    RE reflects the ability of a regulatory program to achieve
all the emission reductions that could have been achieved by full
compliance with the applicable regulations at all. sources at all
times.  The precise degree to which all affected sources comply
with a particular regulation over time is virtually impossible to
ascertain without continuously monitoring emissions at all
sources.  RE can be estimated, however, by evaluating the success
of a regulatory program at a few sources and extrapolating the
results to others.

    RE requires an understanding of a source's uncontrolled
emissions and the control placed on that source, rather than the
controlled emissions.  As demonstrated in Section 4, the RE value
is applied to adjust the control efficiency and is not applied to
the emission estimate directly.   For example, 80 percent RE means
the control effectiveness is actually 80 percent of the estimated
control efficiency; it does not mean that actual emissions are 20
percent greater than estimated.

    The appropriate method for determining and using RE depends
upon the purpose for the determination:  compliance, program or
inventory.  RE discussed outside the particular purpose may be
generically referred to as control effectiveness.  The following
three common uses for a control effectiveness estimate have
historically been called rule effectiveness:

•    Identifying and addressing weaknesses in control
    strategies and regulations related to compliance and
    enforcement activities (more accurately called Compliance
    Effectiveness)

•    Defining or refining the control strategy necessary to
    achieve the required emissions reductions designated in
    the CAAA (more accurately called Program or SIP Design
    Effectiveness)

    Improving the accuracy or representativeness of emission
    estimates across a nonattainment area (hereafter called
    Rule Effectiveness)

Each user needs to determine the effectiveness of rules and
controls in reducing emissions to the desired level as it relates

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to the specific purpose.  For example, SIP planners are concerned
with the ability of the SIP strategy to meet specific ambient
pollutant targets.  Compliance personnel are interested in the
relationship between actual.and permissible emissions for a
particular source or source category.  Inventory personnel need
to know the expected exceedance of emissions from the base
estimate.  This document concentrates on RE; Program and
Compliance Effectiveness will be addressed in subsequent
guidance.

1.3 RULE EFFECTIVENESS FOR BASE YEAR INVENTORIES

    The inventory RE is an adjustment to estimated emissions data
to account for emissions underestimates due to compliance
failures and the inability of most inventory techniques to
include these failures in an emission estimate.  The RE
adjustment accounts for known underestimates due to noncompliance
with existing rules, control equipment downtime or operating
problems and process upsets.  The result is a best estimate of
actual base year emissions, leading to more reliable estimates ef
expected emission reductions a-nd control measure effectiveness in
future years.  EPA requires that base year SIP inventories apply
and report RE.3

    Base year inventory RE considers that emission changes
brought on by growth,  production changes,  etc.  are artifacts that
should be excluded when determining RE.  RE simply adjusts the
estimated emissions for the effects of noncompliance.    By
definition, all source categories for which a regulation exists
should have an RE value between zero arid 100 percent (i.e.,
source categories for which no regulation exists would have no RE
factor associated with them).   To say that a particular
regulation was 100 percent effective would mean that the
regulatory agency could ensure complete and continual compliance
at all sources covered by the regulation,  with no incidence of
control equipment failure or process upset at any source and no
sources evading control requirements.  To say that a regulation
was zero percent effective would mean that no sources in the
category had made any effort to comply with the applicable
regulation.  RE cannot be less than zero or greater than 100 by
definition.

    The connection between SIP rules and actual emissions
reductions is that State or local agencies must assume that there
will be less than 100 percent compliance of rules in the absence
of other information.   Otherwise,  rules will not actually achieve
the intended reductions mandated in Section 182(b)(1)  of the
CAAA:  15 percent over 6 years and 3 percent per year thereafter
until  attainment is reached.

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1.4 FACTORS AFFECTING RULE EFFECTIVENESS

    There is no succinct mathematical formula that adequately
accounts for the many different variables influencing RE,
although it can be thought of as a complex function of the
following types of factors:  the nature of the regulation, the
nature of techniques used to comply with the regulation, the
performance of each source in complying with the regulation, and
the performance of the implementing agency in enforcing the
regulation.  Table 1-1 lists specific examples of each type of
factor.  The list is not exhaustive, however, it demonstrates the
large number and wide variety of factors that- affect RE.

1.5 CALCULATING AND APPLYING RULE EFFECTIVENESS

    The remainder of this document explains the calculation of RE
values and the adjustment of base year emissions for RE.  Every
base year SIP inventory must apply RE according to the guidelines
set forth herein.  The process of examining and applying RE
entails the basic steps listed in Table 1-2.  These steps are  -
explained in detail in the following chapters.

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	TABLE 1-1.  FACTORS INFLUENCING ROLE EFFECTIVENESS
Nature of the Regulation
•     possible ambiguity  or deficiencies in wording
      level  of detail of  recordkeeping required
      level  of complexity of compliance determination
      inadequate test methods

Nature of Techniques Used to Comply with Regulation
      level  of confidence in long-term capabilities of control technique
      (i.e.,  whether  the  emissions control is prone to failure or
      degradation  even with adequate attention)
•     complexity of control technique  (i.e., likelihood that operator
      error  or variability in operator technique could affect
      compliance)                                        *
      potential for fugitive emissions not ducted to control device
      (i.e.,  adequacy of  emissions capture system)

Performance of Source in Complying With Regulation
•     trained individual  responsible for complying with environmental
      regulations
      schedule for maintenance and inspection of control equipment
      adequacy of  recordkeeping  practices  (i.e., can compliance be
      determined from available  records?)
      ensurance of compliance over time,  considering the previous record
      of  process upsets or control equipment malfunction
      timeliness of response to  notices of violation

Performance of Implementing Agency in  Enforcing Regulation
      attention and resources directed at this source or source category
      communications  effort, with respect to compliance requirements
      completeness of data maintained on file
      thoroughness in training inspection personnel
      timeliness and  thoroughness of inspections
      adequacy of  follow-up on noncomplying sources	

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                                                                  \
   TABLE 1-2.  APPLYING RE IN BASE YEAR SIP INVENTORIES
      Step
              Considerations
Determine
relevant
emissions
categories

Identify exempt
sources
Calculate a RE
value  (%) for
each relevant
category
Calculate
control
efficiency for
each affected
source
Calculate base
year emissions
(adjusted for
RE)
Document RE
calculations
Source categories which are subject to
emission controls (i.e., there is a rule
in place) during the year of inventory
should be considered.

Emissions from sources with
uncontrolled, directly determined or
permanently eliminated emissions are
exempt from adjustment for RE.

Agencies calculate RE values derived
from an SSCD study,  the questionnaires
included in this guidance or the default
value.  Questionnaires require a survey
of sources in the categories identified
in the first step.

A reasonable estimate of the emissions
control efficiency for each source is
essential to the RE calculation.  This
efficiency may be measured or estimated
based on the control device or estimated
based on the rule in place.

Emissions are adjusted for RE as
described in this document using
uncontrolled emissions, control
efficiency and the RE value; these
emissions are the SIP base year
emissions.

When submitting the SIP inventory,
agencies should document the procedures
and calculations made to show that RE
has been appropriately addressed,
including criteria used to exempt
sources.

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1.6 REFERENCES

1.  State Implementation Plans; Approval of Post-1987 Ozone and
    Carbon Monoxide Plan Revisions for Areas Not Attaining the
    National Ambient Air Quality Standards; Notice, Federal
    Register, Vol. 52, No. 226, November 24, 1987.  pp. 45044-
    45122.

2.  U.S. Environmental Protection Agency, Procedures for
    Estimating and Applying Rule Effectiveness in Post-1987 Base
    Year Emission Inventories for Ozone and Carbon Monoxide State
    Implementation Plans, Office of Air Quality Planning and
    Standards, Research Triangle Park, NC,  June 1989.

3.  U.S. Environmental Protection Agency, Emission Inventory
    Requirements for Ozone State Implementation Plans,
    EPA-450/4-91-010, Office of Air Quality Planning and
    Standards, Research Triangle Park, NC,  March 1991.

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                            SECTION 2
          PROCEDURES FOR ESTIMATING CATEGORY-SPECIFIC RE
2.1 DETERMINING SOURCES FOR APPLICATION OF RULE EFFECTIVENESS

    Every source subject to an emission control regulation during
the inventory period should be considered for application of RE.
For many nonattainment areas, the list of Control Techniques
Guidelines  (CTG) categories  (Table 2-1) provides a starting point
to identify regulated sources.  It is important to include all
regulated sources, regardless of whether the regulation had
received official EPA approval prior to the inventory period.  In
some cases sources are exempted from emissions regulations if an
emission cap  (e.g./ 25 tons VOC per year) is not exceeded as
defined by the emission control rule.  These sources are not
necessarily subject to RE, although a State or local agency may
choose to include these sources if compliance with the emissions
cap is a known problem.  Once the affected emissions categories
and sources have been identified, each source is ^reviewed to
determine the appropriate RE application.

2.1.1  Excepted Sources

    The following sources are exempt from the RE adjustment:

    sources where no -controls are required (i.e., the source
    is unregulated)

    sources for which control is achieved by means of an
    irreversible process change that eliminates the use of
    VOC or the potential for CO emissions

    sources for which emissions are calculated by means of a
    direct determination

    For sources that are affected by a rule but are completely
uncontrolled, a RE of zero percent should be recorded in the
inventory.  Sources using an irreversible process change to
control emissions should be assumed to be achieving 100 percent
RE.  When emissions can be calculated by means of a direct
determination, RE falls out of the calculation and, thus, is not
applicable  (i.e., the emissions estimate is not contingent on the
effectiveness of controls).  For all other types of sources, RE
should be applied in a manner consistent with Section 3.

    Uncontrolled Sources are exempt from application of RE.  RE
does not need to be determined for sources that are completely
uncontrolled, including cases where the source is making no
attempts at compliance (illustrated by the first screening
question on the point source questionnaire (Appendix A)).  In
this situation, a regulation is considered to be totally

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   TABLE 2-1. SOURCE  CATEGORIES  COVERED BY EPA CONTROL
                TECHNIQUES GUIDELINES  (CTGs)
                       Source Category
CTG Group
Categories Predominated by Point  Sources
     Gasoline Loading Terminals                                    I
     Gasoline Bulk Plants                                         I
     Fixed Roof Petroleum Tanks                                    I
     Miscellaneous Refinery Sources                                I
     Surface Coating of:                                           I
          Cans                          "                          I
          Metal Coils                                              I
          Fabrics                                                  I
          Paper Products                                           I
          Automobiles and Light Duty Trucks                        I
          Metal Furniture                               *          I
          Magnet wire                                              I
          Large Appliances                                         I
          Miscellaneous Metal Farts                               II
          Flat Wood Paneling                                      II
          Graphic Arts                                            II
     Leaks from Petroleum Refineries                              II
     External Floating Roof Petroleum Tanks                       II
     Gasoline Truck Leaks and Vapor Collection                    II
     Synthetic Pharmaceutical Manufacturing                       II
     Rubber Tire Manufacturing                -                    II
     Equipment Leaks from Natural Gas/Gasoline Processing        III
     Plants                                                     III
     Manufacture of HOPE,  PP, and PS Resins                      III
     Fugitive Emissions from SOC, Polymer, and Resin             III
     Manufacturing Equipment                                    III
     Large Petroleum Dry Cleaners
     SOCMI Air Oxidation Processes
Categories Predominated by Area Sources
     Service Stations - Stage I                                    I
     Cutback Asphalt                                              I
     Solvent Metal Cleaning                                       I
     Commercial Dry Cleaning .	II
                                   10

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ineffective.   The  RE  for such a source would be zero and should
be recorded as such in  the  base year inventory.

    Irreversible Process Changes.  An irreversible process change
(in the context of this guidance)  involves a process modification
or equipment substitution that completely eliminates solvent use
from the production process.   Irreversible process changes thus
preclude application  of RE.   Irreversible changes require that
the process cannot be quickly or easily reversed.  Examples of
this would be  substituting  a  hot-melt lamination process for
solvent-based  adhesives and installing powder coating equipment
to replace solvent-based coatings  and equipment.  In general, the
use of "exempt" solvents or compliance coatings2 would  not
constitute an  irreversible  process change.  Although
incorporating  these materials into the production process may
involve the installation of new equipment or the total redesign
of a production line, a total elimination of the potential VOC
use is required to be considered irreversible.   (EPA recognizes
that industries may switch  back to old equipment and solvent-
based coatings; State and local agencies should exercise judgment
in defining irreversibility.)   Sources controlling emissions by
an irreversible process change should be assigned a RE of 100
percent in the inventory because the nature of the control
technique ensures  continual compliance over time.

    Direct Determination is one in which emissions are calculated
directly  (e.g., explicit records for each type of coating and/or
solvent used)  rather  than from estimates of uncontrolled
emissions and  level of  control.  Any calculation that involves
estimates of production rates,  capture efficiency, transfer
efficiency or  solvent consumption  rates typically does not
qualify as a direct determination.  Due to the importance of
direct determination, it is discussed in more detail below.

2.1.2       Direct Determination of Emissions

    As previously  stated, direct determination means that no RE
adjustment is  necessary when  computing base year emissions.  That
is, the emission estimate is  not affected by a source's
compliance or  noncompliance with rules.  Where an emissions
measurement is made with a  high degree of certainty, RE
adjustment should  not apply to that source. When reporting the RE
value for these sources,  use  100 percent rather than zero or "not
applicable."3  The benefit of directly  determining emissions  is
that an accurate calculation  of emissions is made without the
inherent uncertainties  of compliance and control efficiency.
 Compliance coatings include waterborne, low-solvent  (high  solids) and powder
coatings.

3When reporting RE for sources where a rule applies and emissions were directly
determined, report 100 percent. This  reporting convention will clearly identify
to any inventory  reviewers that RE was considered for the source.

                                11

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2.1.2.1 Criteria for Direct Determination  of Emissions
    For an emissions estimate to qualify as  a direct
determination,  it must meet certain  criteria.  First/ emissions
have to be calculated from explicit  source records.  Second/ no
emissions factors or assumptions  (e.g./ for  solvent content) can
be used in the  calculation.  Generally, if a control device is in
place, the estimate does NOT qualify as a  direct determination.
The most common example of a direct  determination of VOC
emissions is  "mass balance" accounting.  The data for the direct
determination must be accurate and well-documented.  Each region,
state or local  agency may decide what constitutes an appropriate
level of documentation for these data, consistent with EPA
guidelines stated in Section 2.1.2.4.  Supporting documentation
for emissions estimates must be maintained by the State.


2.1.2.2 Example of Direct Determination
    Table 2-2 shows two methods, both mass balance, that would
qualify as direct determination under the  current guidelines.
Both situations imply that detailed  records  are available to the
source and/or the air pollution control agency.
             TABLE 2-2.  DIRECT DETERMINATION SCENARIOS
    Process
  Method
Description
Comment
Bulk
Storage/
Solvent
Use
Solvent
Use
Solvent '
Metering (mass
balance)
Accounting
(mass balance)
1)
2)
1)
2)
3)
Requires documentation by the
source
Generally applies to inks,
coatings and solvents
Requires documentation by the
source (adequate paper trail
such as purchasing records)
Assumes 100 percent
evaporation
Solvent content may be
determined by test or using
manufacturers' records
    To illustrate direct determination, consider a manufacturing
facility with a product coating operation achieving compliance by
using low-solvent or waterborne coatings in lieu of control
equipment.   Emissions are directly determined and calculated by
the following method:
                                12

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    Step 1  determine coating and solvent usage over
            time  (e.g., a typical month during the
            ozone season) from detailed plant
            records;

    Step 2  use manufacturer's specifications to
            obtain solvent content of all coatings
            used;

    Step 3  for each coating used, calculate amount
            of solvent used over time by multiplying
            usage (gal/month) by actual solvent
            content  (Ibs VOC/gal coating), as
            supplied by the manufacturer;

    Step 4  calculate the total amount of solvent
            used over time by adding the amount in
            each coating and the amount of raw
            solvent used for cleanup and dilution
             (Ibs VOC/month);

    Step 5  assume that all solvent used was emitted
            to the atmosphere at some point within
            the plant unless manifests indicate that
            some amount was shipped offsite as waste
            or the source can document that some
            portion was incorporated into the
            product; and

    Step 6  calculate emissions in Ibs VOC/day by
            dividing total solvent emitted (Ibs
            VOC/month) by number of working days in
            that month (days/month).

Appendix C illustrates this example in more detail.

    Another example of direct determination is that estimated by
some type of continuous emission monitoring (CEM)  equipment.  If
used/  such equipment must be capable of determining mass balance
emissions over extended periods of time, and provisions must be
made for malfunction in the CEM equipment itself.

2.1.2.3  Major Classes of Emissions Estimation Techniques
    Table 2-3 lists the major classes of emissions estimation
techniques and their potential for classification as a direct
determination.  Some classes are discussed in detail, although
the salient points are contained in the table.

    StacA: tests/emissions tests are generally excluded as direct
determinations because they are emissions "snapshots" rather than
an accurate assessment of emissions over time.  As such, stack
tests are source-specific emission factors.  However, such tests
                                13

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           TABLE 2-3.  EMISSION ESTIMATION METHODS
    Method      AIRS1  Applicability to Direct Determination
                 Code
Stack Test/
Emissions Test
CEM
Mass Balance
AP-42 Emission
Factors
Other (State)
Emission Factors
Engineering
Analysis/ Other
Methods
1
1
2
3 or
8
5 or
9
4
Stack or emissions tests represent a
"snapshot" of emissions at a single point in
time and are not considered direct
determinations . However, results of one or
more emissions tests, used in conjunction
with frequent tests of control device
performance and a complete analysis of
capture as well as control efficiency, may
be considered as a direct determination in
certain cases.
Continuous emissions monitoring (CEM) for
VOC and/or CO is theoretically possible.
CEM would preclude any RE adjustment
provided the CEM equipment is operating
properly throughout the estimation period.
Mass balance is the technique usually
considered for direct determination,
provided adequate documentation of
throughput and (VOC) content are available.
This technique generally is used for
evaporative sources. Use of estimated
control/capture/transfer efficiencies in a
calculation of emissions disqualifies the
estimate as directly determined. The effect
of regulatory or physical controls can only
be estimated from the known inputs and
outputs from the process ,
AP-42 emission factors are not direct
determinations .
Emission factors in general cannot be
considered direct determinations .
Determination based on engineering
principles or judgment cannot be direct
determination .
Aerometric Information Retrieval System
                                14

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maybe considered as direct determinations in conjunction with
all of the following other data:

•   Records of control equipment function  (efficiency and
    upsets) throughout the period.  These include daily
    records of upsets and periodic  (i.e., at least monthly)
    determinations of actual efficiency and maintenance.

    A detailed and applicable study of capture efficiency.
    Emissions for processes that emit VOC are frequently
    estimated at the building vent or control device outlet.
    These estimates do not account for the control device
    capture efficiency and emissions which "leak" from the
    building.  These losses can be very significant prior to
    reaching the control device and must be factored into the
    emissions estimate.

    Documentation that the emissions test remains applicable
    to the process and operations at the source.
                                                 *              _
    Mass balance is the common term for estimating emissions
based on subtracting the known outputs of the process from the
inputs to the process.  This is a well—respected method for
determining emissions of SOX from combustion  processes  based on
sulfur inputs to the process and chemical stoichiometry.  To
determine emissions for VOC, any organics incorporated in the
product plus the amount of process fugitives captured (e.g./ the
amount of recycled solvent) is subtracted from the total VOC
(typically solvent) input.  No control or capture efficiency is
necessary for this calculation.  The efficiency of the regulatory
or physical control is solely determined on the basis of measured
process inputs and outputs.  As discussed previously, this
measurement process is restricted to documented metering or
accounting of inputs and outputs.

    Emission factors are not appropriate as direct determinations
of emissions because they are not specific to the particular
source.  Even with the information discussed for emissions tests
on capture efficiencies and control device operation, emission
factors will not produce an estimate sufficiently reliable to the
specific source to qualify as a direct determination.

2.1.2.4  Documenting Direct Determination
    The local or State air pollution control agency is ultimately
responsible for determining the adequacy of documentation and
application of directly determined emission estimates.   Local and
State agencies should maintain records necessary to document
direct determinations and should be prepared to produce this
documentation upon EPA's request.  EPA is not requiring that
these records be submitted with the SIP inventory;  complete
submittal of this information would unnecessarily increase the
effort of the submittal process.
                                15

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    The following information illustrates the level of
documentation required to support direct determination of surface
coating emissions:

    •   Solvent  (VOC) content of each coating type
    •   Accurate measure of the amount of each coating
    •   Amount of thinning and cleanup solvent
    •   Amount of waste solvent disposal offsite
        Adequate oversight of these records by State or local
        agency

Table 2-4 suggests criteria for meeting and documenting these
requirements.

2,2 OVERVIEW OF APPLICABLE APPROACHES FOR DETERMINING RE

    In determining an RE value for adjusting the base-year VOC
emissions inventory, State and local agencies may elect to
(1) use an across-the-board RE presumption of 80 percent for all
sources;  (2) use the questionnaire approach to determine a
category-specific RE value for both point sources and area
sources; or  (3)  use or design a study specific to a category in
accordance with the procedure developed by SSCD.  The following
sections discuss each of these methods for determining RE.

2.3 DEFAULT VALUE APPROACH

    In general,  the 80 percent default RE value is used in the
absence of a local category-specific evaluation (i.e.,  the
questionnaire approach or the SSCD study approach).  In essence,
the 80 percent default value assumes that the ability to use
control devices and existing rules to achieve a 100 percent
compliance rate is only 80 percent effective.  Therefore, the
base year emissions inventory must be adjusted by this factor to
ensure that the amount of emissions reductions necessary to
achieve the CAAA-required reductions in VOC emissions can be met.
The RE value should be applied as discussed in Section 2.4,
Questionnaire Approach.

      A number of surveys- were conducted to determine a
representative default RE value,  one of which was conducted by
OAQPS of States in the Regional Oxidant Model Northeast Transport
(ROMNET) region.  This survey indicated that regulations and
controls were approximately 80 percent effective,  on average, in
achieving the target emissions reductions.

    Subsequent examination of the 1989 SSCD studies have allowed
OAQPS to reexamine the 80 percent default value.  The results of
the 1989 SSCD RE studies conducted by States in 7 of the 10 EPA
Regions also show an average RE value of approximately 80 percent
when averaging the results obtained from three alternate methods
(including the method contained in this guidance document) used
to calculate RE for the SSCD study.  Some of the RE studies
                                16

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      TABLE  2-4.   DOCUMENTING DIRECT DETERMINATION FOR
                     SURFACE COATING


SOLVENT  (VOC) CONTENT

Document Solvent or VOC Content of Every Coating
     •    Periodic  Testing of Actual Coatings
     •    Manufacturer's  Specifications for Coatings that Include
         Solvents
         Material  Safety Data Sheets  (MSDS) with Information on Total
         VOC Content
     •    Reflect Coatings in Use during the Inventory Period

Total VOC Emitted = VOC Content x Total  Coating Consumed
COATING OR SOLVENT CONSUMPTION

Record Total Coating (or Solvent)  Use Regularly
        Daily  or  Batch by Batch Basis
     •   Process by Process
     •   Coating by Coating

Use Purchasing Records if Necessary

Make Records Available during Inspections

Source May Submit Monthly or Quarterly Summaries
THINNING AND CLEANUP SOLVENT

Include Thinner and Cleanup Solvent Consumption
        Daily  or Batch by Batch Records
     •   Monthly or Quarterly Summaries



SOLVENT DISPOSAL/RECYCLE

Give Cre~ :_t for Offsite Disposal/Treatment
     •   ^obmit Waste Transfer Records with Information on Amounts
        Shipped



ADEQUATE OVERSIGHT

Inspect Regularly

Check Facility's Summary Data  against  Daily Records during Inspection

Check Records (e.g.,  Daily Summaries)  against Records Kept "on the
Floor."

Investigate and Resolve any Discrepancies	    	      	
                                17

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indicated values in excess of 100 percent.  These values are
inappropriate in reviewing inventory RE.  Values greater than  100
percent imply that emissions for a category are less than
estimated.  The causes of "over-compliance"  (i.e., decreased
production) in these studies are already accounted for in the
inventory emissions estimates.  Values greater than 100 percent
were set equal to 100 percent.  The results varied from about  70
to 90 percent, depending on the selected calculation method.

    It is difficult to estimate a particular category's RE for a
particular area based on a small subset of studies such as the
1989 SSCD RE studies.   Where other data are unavailable to
estimate category-specific RE, the 80 percent default value is
the most appropriate based,on the information currently
available.

2.4 QUESTIONNAIRE APPROACH

    The intent of the questionnaire approach is to determine a
categrory-speci.fic RE value to adjust the baseline*VOC emissions'
inventory for less than 100 percent regulatory compliance in a
nonattainment area.  This approach involves the use of
questionnaires designed for both point and area sources and is
based on information on file with the source and personnel
familiar with the sources included in the study (Appendices A and
B).  (Sources to be included in the process must pass a
preliminary screening test.  An RE number is determined for each
category in each nonattainment area.)

2.4.1  Level of Effort

    The categories representing at least 80 percent of the
emissions inventory must be surveyed with the questionnaire.  The
questionnaires contain a series of generic questions covering
various factors which affect the RE determination.  These factors
include the nature of the regulation,  the nature of techniques
used to comply with each regulation,  the performance of the
source in complying with the regulations,  and the performance of
the implementing agency in enforcing the regulations.  The
questionnaire is designed to be answered using only available
source file information,  thus alleviating the need for source
inspections.  Prior to each source evaluation/  the complete
source file information is reviewed including reports of previous
visits and inspections.  Information pertaining to potential
deviations or deficiencies in State regulations must also be
reviewed prior to taking this approach.  In many cases,
knowledgeable inventory staff may be able to complete the
questionnaires for a single source category in one—half day or
less.
                                18

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2.4.2  Procedure

    The procedure involves the use  of  two  generic questionnaires
that are based on the  factors listed above and in Table 1-1.   One
questionnaire is used  for individual point sources (see Appendix
A) and another for area  source categories  (see Appendix B).
Table 2-1 listed source  categories  for which  CTGs have been
issued and provides  a  good starting point  for State and local
agencies to determine  which questionnaire  to  apply.

    Many States contain  more than one  nonattainment area,  raising
the issue of whether RE  should be estimated on a  local or
statewide basis.  In general, this  procedure  should be used  to
determine unique RE  estimates for each nonattainment area, except
in cases where statewide regulations are implemented by a  single
agency throughout the  State.  In this  case, all nonattainment
areas in the State may employ a single value.   The appropriate
EPA Regional Office  should be contacted for guidance if there is
any question of whether  local or statewide estimates are
appropriate in a particular State.

2.4.2.1  Identifying Personnel to Perform  the Evaluation
    In most cases, representatives  from the State or local
agency's SIP planning  or inventory  group and  compliance group
should oversee the RE  evaluations described in this document, but
this selection may vary  based on the individual agency and
personnel experience.   (The person  conducting each evaluation
will be hereafter referred to as the "evaluator.")   One of the
goals of incorporating RE in the base  year inventory is to have
planning personnel become more aware of the extent to which
sources are complying  with SIP regulations and the actual
emission reductions  that have resulted.  The  evaluator should
enlist the aid of the  local inspector(s) most  familiar with  each
source.  The role of the EPA Regional  Office  generally will  be to
review the results of  the individual evaluations  and/or the  final
RE estimates.  In specific cases where this arrangement is not
satisfactory, States or  local agencies may negotiate with  the
Regional Offices to  modify the respective  roles.

2.4.2.2  Preliminary Screening of Sources
    Each point source  chosen should be subjected  to the
preliminary screening  test at the beginning of the point source
questionnaire.  This screening will determine  the appropriateness
of evaluating RE by  means of the questionnaire procedure for the
chosen sources.  The questionnaire  should  NOT  be  used to
determine RE for the chosen source  if  any  of  the  following is
true:

•   the source is not  regulated4
 Unregulated sources which are controlled should have equipment downtime, actual
operating efficiency and process upsets factored into the emissions estimate,
although these sources  are not technically subject to RE.

                                19

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•   the source achieves emissions  reduction by means of  an
    irreversible process change that completely eliminates
    VOC from the process

•   emissions from the source are  calculated by means of a
    direct determination

    Sources for which any of the above is true should be excluded
from the Questionnaire evaluation  and are exempt from the
adjustment of emissions for RE.  These exclusions were discussed
in detail in Section 2.1.1.

2.4.2.3  Choosing Sources to Evaluate
    State and local agencies choosing to develop category-
specific RE estimates may  (1) use  the questionnaire procedure for
ALL regulated stationary source categories in their inventories
or (2) use the questionnaire for 80 percent of their emissions
inventory and a combination of the default value or SSCD study
for the remainder of the emissions.  If a State or local agency
wishes to use the questionnaire approach for a subset of emission
categories/ the following conditions must be met.   At least
80 percent of the total pollutant-specific emissions (e.g., VOC)
must be covered by questionnaires  and all categories representing
5 percent or greater of the pollutant-specific emissions must use
the questionnaire.  Both conditions (80 percent coverage of total
point source pollutant emissions and every category representing
5 percent or more of the total point source pollutant emissions)
must be met for the questionnaire  approach.

    The most accurate way to estimate RE for point source
categories would be to evaluate all sources in each category for
which a regulation exists and average the results.  Since this
would place an unreasonable burden on resources and time for the
agency performing the evaluation,   agencies should evaluate RE
sources in each category for which a regulation exists according
to the following guidance.   If there are ten or fewer sources in
a category, all sources should be  included.  If there are more
than ten,  choose ten at random,  complete the questionnaires and
determine if the sample size is adequate or needs  to be expanded.
The point sources should be chosen randomly to avoid biasing the
results.  To assure statistical accuracy, use the  procedure
outlined in Appendix D for determining the sample  size.   (Area
sources as defined by the emission inventory will  be evaluated by
category.)

    One possible method for choosing random point  sources is for
the evaluator to obtain a list of  all sources in the local
inventory,  grouped by source category.   These sources should
include the numerical identification codes and any other details
necessary to obtain the appropriate file information.  The
evaluator might then enlist the aid of another employee who is
unfamiliar with both the sources and the numerical coding system
of sources in the air program.  This employee would be presented


                               20

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with a list  of  only the numerical identification  codes,  not the
company names,  of all sources in the inventory  grouped by source
category,  and asked to randomly choose a statistically valid
sample from  the necessary sources in each point source category
for which  a  regulation exists.  Alternately, there  are many
popular software packages (e.g., Lotus®) which  are  able to
generate random numbers with a list of sources.

2.4.2.4 Sources with Control Efficiencies Greater Than 95 Percent
    Source emissions may be artificially inflated when the 80
percent default value for RE is applied to sources  with stated
control efficiencies greater than 95 percent.   This is of
particular concern when dispersion modeling is  used.   To ensure
that emissions  estimates are as accurate as possible,  EPA has
developed  three different options to accommodate  this  situation.
Before selecting one of the following options,  States  should
attempt to verify the capture and control
efficiencies of these highly-controlled sources.

Option I:

1.  Identify sources with stated control efficiencies  greater
    than 95  percent.

2.  For these sources, apply the Questionnaire  to determine the
    actual RE for the source.  If the Questionnaires cannot be
    completed by the November 15,  1992 deadline,  an adjustment
    can be made afterwards.5  In these  areas,  Option II must be
    used for the November 15, 1992 inventory submittal.

Option II:

1.  Apply  the 80 percent default value for RE to  the sources with
    control  efficiencies greater than 95 percent  in the base-year
    inventory.

Option III:

1.  Identify sources with stated control efficiencies  greater
    than 95  percent.

2.  For the  1990 base-year inventory, use option  I  or  II.

3.  After  submitting the 1990 base-year inventory,  develop an
    alternative questionnaire to determine RE for these highly-
    controlled  sources.
 EPA prefers  that  adjustments be made prior  to  the public hearing on the
inventory, but no later than any other hearing held on the rate of progress plan
and attainment  demonstration  (see  Memorandum  of  September  29, 1992,  Public
Hearing Requirements for 1990 Base-Year Emission Inventories for Ozone  and CO
Nonattainment Areas, from John Calcagni and Bill Laxton to Regional Air Division
Directors).

                                 21

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4.  Obtain EPA  approval  for the RE questionnaire.

5.  Apply the alternative RE questionnaire to the identified
    sources.

6.  Adjust the  base-year emission inventory after the new RE
    values have been calculated for these sources.5

2.4.2.5  Answering  the Questionnaires
    The evaluator should complete one point source questionnaire
for each selected point  source in the sample that passes the
preliminary screening test and one area .source questionnaire for
each area source category.  The questionnaires are designed to be
answered using  available file information only.  No dedicated
source inspections  are required.  The complete file information
on a particular source,  including reports of previous visits and
inspections, should be obtained by the evaluator prior to
answering the questionnaire.  To answer the questionnaires, the
evaluator should confer  with the State or local compliance
inspector most  familiar  with the source or soured category being
evaluated.  If  an answer cannot be ascertained, the space marked
"unsure" should be  indicated on the questionnaire.

    In addition, the evaluator should obtain any information
relating to potential deviations or deficiencies in the State or
local regulations.  The  most helpful information would be in the
SIP-call follow-up  letter sent to the State Air Program Director
from the corresponding EPA Regional Air Division Director.  This
letter delineates specific deficiencies that EPA required to be
corrected in response to the SIP-calls for nonattainment areas in
that State.  Another source of information is the document,
Issues Relating to  VOC Regulations,  Outpoints,  Deficiencies, and
Deviations, issued  on May 25,  1988 by AQMD.   The evaluator should
confer with the EPA Regional Office to ascertain the most current
and applicable  information on regulation deficiencies.

2.4.2.6  Determination of Rule Effectiveness Values
    The answers to  the questions on the questionnaires each have
a point value associated with them.   After answering each
question with the most appropriate response,  the evaluator should
sum the point values of  the answers for each section and record
the sub-totals  and/or totals in the space provided on the last
page.   Section  3 describes how to apply these RE values in the
emission inventory.

    Determination of the RE value for point  source categories has
been revised since  the Post-87 RE guideline  to make the category
value more representative.   Formerly,  a simple arithmetic average
of the questionnaire totals produced the RE  value to be used for
all sources in  that category (i.e.,  every completed questionnaire
received equal  weight).  The former procedure has been replaced
by a revised,  emissions-weighted average to  accommodate the true
effect on category  emissions.   By using an emissions-weighted


                               22

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average, the  questionnaire  RE  value  better  estimates  the  effects
of higher  (or lower)  RE  at  large  emissions  sources  on the overall
category emissions.   Where  large  emissions  sources  have better
compliance  (RE closer to 100 percent)  than  small  emissions
sources, emissions  for the  category  will more  accurately  reflect
the effect  of the compliance level of  the larger  facilities.

    The questionnaire results  should be weighted  by uncontrolled
emissions.  This weighting  system increases the overall influence
of the estimated RE  at larger  magnitude emitters  on the category
emissions.  The questionnaire  results  from  the surveyed
facilities  should be treated in the  following  manner:


                       JL      Uncontrolled Emissions
                RE     = V [RE. *	:	-]
                 etttgory  *-^   j   n
                             2_j Uncontrolled Emissions
                             j-i
    where:  n  is the number  of  facilities with  completed
            questionnaires

    Table 2-5  illustrates the use  of this equation  and  the
calculation of the RE value.  The  State or  local  agency may  be
asked by the Regional Office to support RE  values calculated from
the questionnaires.  The State  or  local agency  should be prepared
to document the procedures and  information  used to  complete  the
questionnaires.

2.5 SSCD STUDY APPROACH

2.5.1  Purpose of the Study

    The purpose of the SSCD  study  is to provide the States,  local
agencies and EPA with criteria  and procedures for conducting an
RE study or evaluating the degree  of source compliance  with
existing rules.  In the context  of the SSCD study,  RE means  the
extent to which a rule actually  achieves  (or has  the capability
of achieving)  desired emission  reductions, both in  terms of  the
reductions projected for that rule, and the reductions  that  would
ordinarily be  achieved if the rule were properly  implemented.
Like the questionnaire approach, the SSCD study only applies to
the geographic area in which it  is conducted.   In contrast to the
generic questionnaire approach  for both point and area  sources,
each SSCD study is individually  designed and applied to a single
point source category.

    The principal goals of the  SSCD study procedure are:   (1) to
determine the  effectiveness of  rules for a  specific source
category in a  specific nonattainment area according to  the
quantitative criteria set forth  in this protocol; and  (2) to
                                23

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   TABLE 2-5.  EXAMPLE  OF WEIGHTED RE VALUE USING  QUESTIONNAIRE

                                                          RE Value
              RE from     Uncontrolled Height Weighted    for
 Facility  Questionnaire    Emissions   Factor1     RE2    Facility3
A
B
C
D
E
F
G
H
I
J
100%
60%
80%
80%
85%
90%
65%
75%
95%
80%
500
100
75
200
50
30
120
35
25
60
0.42
0.08
0.06
0.17
0.04
0.03
0.10
0.03
0.02
0.05
0.42
0.05
0.05
0.13
0.04
0.02
0.07
0.02
*0.02
0.04
100%
60%
80%
80%
85%
90%
65%
75%
95%
80%
TOTAL

CATEGORY RE VALUE4
1,195
1.00
0.86
                                 86%
1  Weight factor equals facility's uncontrolled emissions over total uncontrolled.
2  Weighted RE equals facility's RE from questionnaire times weight factor.
3  Use the RE value from the facility-specific questionnaire  response for that
  facility.
4  All facilities not  included in the survey sample  are assigned the category
  value.
identify  specific implementation problems  which need to be
addressed by  the State, local and EPA  compliance and enforcement
staff in  order to achieve greater RE in  the  future.

2.5.2  Summary of the SSCD Study Approach  Procedures

    The SSCD  study prescribes inspections, emissions tests and
agency audits to compare actual measured emissions to "allowable"
emissions under the existing rules(s).   The  difference represents
the degree  of compliance with the rules  (i.e.,  the RE in
achieving emissions reductions).  The  study  requires that the
source sample size from a single source  category be determined
statistically,  with considerations given to  the allocation of
personnel for inspections.

    The SSCD  study approach consists of  a  two-phase study
including (1)  an office investigation  and  (2)  a field inspection
at the source.   Each study initiated by  a  State or local agency
                                 24

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must receive approval from the EPA Regional Office and
Headquarters.  In general, the field inspection involves
determining the compliance status of a representative number of
sources in a nonattainment area through the calculation of
emissions and the determination of the percent effectiveness of
current regulations.  Sources included in the study are inspected
unannounced.  The elements of the field inspection include the
following:   (1) rule application evaluation/  (2) State inspection
procedures evaluation,  (3) compliance determinations,
(4) emissions quantification, (5)  quality assurance, and
(6) inventory evaluation.  An inspection checklist is developed
and used for each source.  The checklist is comprised of three
sections which are  (1) inventory verification,  (2) regulatory
applicability, and  (3) inspections procedures evaluation.  All
applicable regulations and policies pertaining to the sources
under study are identified and the compliance status of the
sources with SIP rules is determined, differentiating between
procedural and emission requirements.  The office investigation
phase provides a further analysis of program implementation
elements not susceptible to a comprehensive evaluation during a~
field inspection.

    The study identifies problems which can be corrected,
processes corrective action options, and comments on advantages
and disadvantages of each option.   Within one year following the
study, a follow-up audit is conducted to determine whether
corrective actions were implemented.  Finally, the SSCD study
includes an inventory demonstration for the selected source
category which includes the following elements:   (1) field
investigation follow-ups if inventory discrepancies evolve; and
(2) a search for potentially omitted sources including a survey
of source exemption applicability and a ground survey to locate
unregistered sources.

2.5.3  Calculating RE from an SSCD Study

    The SSCD study approach may be applied only to a single
source category for which a given study is designed.  The result
of each study is a category-specific RE estimate for a particular
geographic area and category.  States and local agencies may need
to determine if previously existing SSCD study results remain
valid or if the study is outdated due to industry or regulatory
changes.  Only studies deemed valid for the inventory period may
be used.  To apply the result for SIP purposes, the calculation
must reflect this context.

    The percentage effectiveness .calculations will be based on a
comparison of actual emissions to the allowable emissions for
sources included in the study. These emissions must be documented
as part of the field investigation phase of the study, and the
calculations must be based on emissions testing, sampling and
usage data identified for each source during the investigation.
                                25

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    Percentage effectiveness for base year  inventory  applications
should be calculated according to the procedure  listed below.
Compute separately the total allowable and  actual emissions  for
all sources on the day of the inspection or source test.   The
following equation should be used:
         RE Inventory Method (for SIP inventory purposes)
                         Baseline - Actual

                        Baseline - Allowable
x 100
If the baseline cannot be determined, the following equation, which
calculates the  baseline  from allowable emissions and the  control
efficiency/ is  used:
         % RE =
                        Allowable
                 1 - Control Efficiency6
                                         - Actual
                      Allowable
       x 100
                1 - Control Efficiency
                                       - Allowable
        where:

        Baseline   -   base year inventory  (before control)

        Actual     =   emissions determined during course of study
                      from  mass   balance,   stack  testing,  CAA
                      Section  114 responses,  inspections and/or
                      production  records review

        Allowable  =   emissions determined from SIP requirements

        Control Efficiency = control efficiency defined in  the CTG

    This  method   considers  what  emission  reductions  were
    actually achieved and evaluates performance in terms of  the
    magnitude of excess emissions.

    This  method should  be applied  in  any  study  where  the
    results  will  be used to  modify  the  80 percent  rule
    effectiveness  assumption.

    Users requiring more  information should consult SSCD guidance
on the RE approach.
'Control Efficiency calculations are shown in Section 3.2.1.
                                26

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2,6 USING RESULTS FROM SSCD STUDIES, QUESTIONNAIRES AND THE
    DEFAULT

    The procedural approaches to determine RE using the
questionnaire and the SSCD study are vastly different.
Figure 2-1 shows a summary comparison of the questionnaire
approach  (Appendices A and B) versus the SSCD study approach.
The shaded boxes represent common steps.

    The State or local agency may use the questionnaire approach
or may apply the default value across the entire inventory.
Where an SSCD study result is used or all source categories are
not covered by the questionnaires,  a combination of methods must
be used to complete the inventory.   Table 2-6 lists the
combinations available to the State and local agencies when an
SSCD study is used or the questionnaire approach does not cover
all categories.
                               27

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       QUESTIONNAIRE
 STEP
         SSCD STUDY
               Ti
Perform Screening for Applicable
            Sources
 (Repeat Step  (2)  as  Necessary)
     Complete Questionnaire
               I
        Score Evaluation
 ,,',„'
                      C*t
 (1)





 (2)





 (3)





 (4)





 (5)



 (6)




 (7)



 (8)



 (9)



 (10)



 (11)
                                          Select One Point Source Category
               1
 Develop  Appropriate Protocol/
 Receive  Approval from SSCD or
	Region   	 	
                                                         1
               1
     Office Investigation
     Evaluate Current Rule
    	Application	
                                           Field Inspections and Testing

                                                         I
                                          Inventory Accuracy Demonstration

                                                         i
                                                       Report
                                               Corrective  Action  Plan
    Rule Effectiveness Value to
    Apply to Base Year Emissions
    for Each Category
RESULT  .  Rule Effectiveness Value for
          One Category
       •  Improved Emissions Estimate by
          Source
       •  Identification of
          Noncompliance Causes
       •  Corrective Action Plan
 Figure 2-1.  Comparison of the  questionnaire and SSCD  study,
                                   28

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     TABLE 2-6.
COMBINING SSCD STUDY AND QUESTIONNAIRE
APPROACHES
RE Value Based on.
     Approach for Other Categories
SSCD Study
Questionnaires
     Other categories may be analyzed based
     on questionnaires or the 80% default
     value may be applied.

     Remaining categories may use the 80%
     default value provided the minimum
     criteria for applying questionnaire
     defined in Section 2.4.2.3 are met.
                             29

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                            SECTION 3
    APPLICATION OF RULE EFFECTIVENESS  IN BASE YEAR INVENTORIES
3.1INTRODUCTION

This section provides guidance on the application of RE to
emissions inventories and presents the emissions calculation
procedure.  RE must be applied to base year SIP inventories for
ozone precursors and CO, specifically to sources of VOC, NOX and
CO.  Previous SIP inventories considered only VOC and the
majority of current applications will still be for VOC sources.
(Since few emission regulations for non-mobile sources of NOX and
CO existed in 1990, RE is currently not an issue for these
pollutants for base year 1990 inventories.  If these pollutants
are regulated in the future, RE will' need to be applied in
subsequent inventories.)

    RE factors are to be applied for the purpose of more
accurately representing actual emissions.  While iocal RE values-
may be determined on a source category basis, these same factors
should be applied in the inventory on a source-by-source basis.
Applying RE factors to individual sources will increase the
emissions indicated for most sources; therefore, it is important
for air pollution control specialists to understand that the RE
estimates determined by the above procedure are to be used for
emission inventory purposes only.

3.2 CALCULATING RULE-AFFECTED EMISSIONS

    Determination of rule-affected emissions requires three
inventory data elements:  (1) the RE value (percent); (2) overall
control efficiency; and (3)  estimated uncontrolled emissions.
Before applying RE, the relevant sources must be identified as
described in Section 2.  Once an RE percentage has been
determined for each source category and a source has been
determined to be subject to RE,  the emissions from that point or
area source are adjusted.   If the questionnaire approach was
used,  apply the individual questionnaire RE scored for sources
surveyed by the questionnaire; apply the calculated category RE
value to the sources in the category which were not surveyed.
The calculation is done source by source at the emissions
calculation step (typically the segment or process level in the
Aerometric Information Retrieval System (AIRS) for point sources
and category by category for area sources.

    The following equation is used to calculate rule-affected
emissions:

    RE Emissions = Uncontrolled Emissions x (1 -  ( Control Efficiency x RE ) ) .
                                30

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where RE and control  efficiency are expressed as  fractions.
equation clearly demonstrates that RE accounts  for  the
effectiveness of the  control.
The
    Section 2 discussed  the derivation of the RE value.  Control
efficiency and uncontrolled emissions are typical emissions
inventory elements.  Uncontrolled emissions may have to be
backcalculated from the  estimated controlled emissions.  For
example, source tests may account for the control in place.
Control efficiency is a  required SIP data element for control
devices, but control efficiency for RE includes both physical and
regulatory controls.

3.2.1  Control Efficiency

    Regulatory controls  are emission's limits implemented through
either regulatory or physical means.  A solely regulatory control
is typically an emission rate limitation unrelated to a control
device.  For example, an industrial coating operation may be
limited to using a coating of no more than 2 .0 Ibs1 VOC per gallon
coating.  The control efficiency is based on the difference
between the total solvent used prior to the regulation and post-
regulation.

    A physical control is a control device such as an incinerator
or carbon adsorber used  to reduce emissions from a process.
Control efficiency may be reported on the basis of manufacturer's
specifications or emissions testing.  To be reliable, capture
efficiency, actual operating conditions and process and/or device
upsets must be included when estimating emissions.  These
variables may be factored into a single average control
efficiency or emissions may be estimated for each different
operational mode (refer  to emission inventory guidance).

    Application of the RE value is straightforward where the
control is a physical device (e.g.,  a carbon adsorber)  with an
estimated efficiency (e.g.,  95 percent).   When the control is due
to a rule implementation (e.g.,  coatings restricted to no more
than 3 Ibs VOC per gallon),  it is more difficult to determine the
"control efficiency" of  that rule.  However,  there is no
distinction between regulatory and physical controls for the
purpose of applying RE.

    EPA recognizes that a control efficiency inherent in a
regulation (e.g.,  an emission limit such as Ibs VOC per gallon
coating) may be difficult to determine.   In these cases the best
option is to determine emissions before and after a regulation
was adopted from existing source records.   This may be impossible
if a source was never in operation or inventoried prior to rule
adoption or if process changes have made such comparisons
meaningless.   A second option is to use the control efficiency
estimate used in the development of the CTG or State/local rule.
                                31

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    Questions have been raised regarding the control provided by
rules specifying types of storage  tanks  for petroleum product
storage.   The best way to calculate  control efficiencies for
storage  tanks is to calculate emissions  per unit product based on
the AP-42  equations before  (e.g.,  a  fixed-roof tank) and after
 (e.g., an  external floating roof tank) rule adoption.  This
course may be both resource and time intensive.   Representative
control  efficiencies for gasolines and distillate oil from Table
3-1 may  be used instead of detailed,  tank-by-tank calculations.
These values  have been derived based on  a wide variety of tank
sizes and  throughputs which indicate that emissions per unit
product  from  a tank type are principally dependent on the vapor
pressure of the contents,  not tank size.1
             TABLE 3-1. DEFAULT PETROLEUM  STORAGE TANK
                        CONTROL EFFICIENCIES
       Material
        Stored
Before Rule
 Condition
After Rule
 Condition
  Default
  Control
Efficiency
  Gasoline RVP7 to
  RVP10

  Distillate No. 2
 Fixed Roof


 Fixed Roof
  External
Floating Roof

  External
Floating Roof
    95%
    91%
  Gasoline RVP7 to
  RVP10

  Distillate No. 2
 •Fixed Roof


 Fixed Roof
  Internal
Floating Roof

  Internal
Floating Roof
    98%


    92%
  Gasoline RVP7 to
  RVP10

  Distillate No. 2
  External
Floating Roof

  External
Floating Roof
  Internal
Floating Roof

  Internal
Floating Roof
    60%


    20%
    Where a  regulatory or inherent control efficiency must be
determined to  apply RE,  the inventory preparer  should consider
and use the  procedures listed below to make this  determination.
These procedures  are listed in order of preference  and
reliability:

1)  Make a  "before  and after regulation" determination based
    on historical inventory records for each affected source
    or the category.

2)  If (1) is  not possible,  refer to the local  SIP
    development dpcumentation that supports the planned or
    expected control level anticipated from the
                                 32

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    regulations(s) applicable to the category.  Use this
    control level as the control efficiency for sources
    covered by the rule(s).

3)  As a final resort, refer to Appendix E to estimate the
    expected control effectiveness for CTG categories.  This
    listing has been developed from CTG summaries and is only
    to be used to approximate control efficiencies for RE
    application where no other data are available.  This
    listing presents ranges in some cases; use the lower end
    of the range unless other justification can be
    documented.  Where the upper end of the range is 100
    percent, this value cannot be used except where direct
    determination or irreversible process change can be
    documented.  EPA has not determined the validity or
    reliability of these control efficiencies for this
    purpose.

3.2.2  AIRS Coding
                                                 *              _
    The AIRS/Facility Subsystem (AFS)  and the AIRS Area and
Mobile Source  (AMS)  are capable of storing RE values and applying
RE to the point and area source inventories,  respectively.  The
procedure involves setting the "SIP Rule in Place" field to "Y, "
"B," "M" or "R."  These codes designate Yes,  BACT, MACT and RACT,
respectively.  [Note:  While the field is called "SIP Rule in
Place," this refers to any rule that is in place in the inventory
area that is expected to reduce emissions, regardless of whether
or not the rule is part of the SIP.]   Any source with these codes
and a nonzero control efficiency will  be expected to have an RE
value.   (Remember that directly determined emissions sources have
a 100 percent RE.)  For emissions calculated using an emission
factor,  process or throughput rate,  and control efficiency, AIRS
can automatically calculate the RE emissions adjustment.  Outside
the AIRS system,  these calculations will have to be performed as
previously described.

    When coding AIRS or other inventory transactions,  all
regulated sources where the regulation has an impact on the
estimated emissions should have an RE  entry in the estimated
emissions.   State and local agencies should code RE values
according to the type of sources (Table 3-2):


    For sources making no attempt at compliance,  RE should be 0
    percent

    Directly determined or irreversible processes that eliminate
    solvent (VOC)  emissions should be  coded as 100 percent

    All other regulated sources should be coded with a value
    between 0 and 100 percent
                                33

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     TABLE 3-2.   CODING RE IN ELECTRONIC INVENTORY SUBMITTALS
       RE Determination
          Coded RE Value
   Uncontrolled Source

   Irreversible Process
   Change

   Direct Determination

   Questionnaire
               0%

             100%


             100%

Weighted score from questionnaire
   SSCD Study
   Default
Study results using SIP inventory
calculation  (%)

              80%
3.3 DOCUMENTING RULE EFFECTIVENESS FOR THE SIP SUBMITTAL

    Rule effectiveness must be documented in the SIP inventory
submittal, consistent with OAQPS Emissions Inventory
Requirements,2'^ the Quality Review Guidelines,4 and  the
individual Inventory Preparation Plans (IPPs).  These
requirements include a discussion of how rule effectiveness was
incorporated into the inventory.  States should clearly annotate
summary emissions tables as either adjusted or unadjusted for
rule effectiveness.  Emission estimates will be reviewed to
ensure appropriate application of Rule Effectiveness in the base
year inventories.  Any deviations from OAQPS guidance on RE
should be discussed in the submittal.

3.4 REFERENCES

1.  Memorandum from David Winkler and David Zimmerman,  TRC
    Environmental Corporation, to Gerri Pomerantz,  Office of Air
    Quality Planning and Standards,  U.S.  Environmental Protection
    Agency, "Control Effectiveness:   Petroleum Product Storage
    Tanks." August 13,  1992.

2.  U.S. Environmental Protection Agency, Emission Inventory
    Requirements for Ozone State Implementation Plans,  EPA-450/4-
    91-010, Office of Air Quality Planning and Standards,
    Research Triangle Park, NC,  March 1991.

3.  U.S. Environmental Protection Agency, Emission Inventory
    Requirements for Carbon Monoxide State Implementation Plans,
    EPA-450/4-91-011, Office of Air Quality Planning and
    Standards,  Research Triangle Park, NC,  March 1991.
                                34

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4.  U.S. Environmental Protection Agency, Quality .Review
    Guidelines for 1990 Base Year Emission Inventories, EPA-
    454/R-92-007, Office of Air Quality Planning and Standards,
    Research Triangle Park, NC, August 1992.
                                35

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                            SECTION 4
                       EXAMPLE CALCULATIONS
    The following examples illustrate how to include RE in the
emissions calculations for several types of facilities.  Most of
these examples are presented on a daily emissions basis.
Typically/ emissions are first calculated on an annual basis.  RE
actually applies to both annual and daily estimates; EPA emission
inventory guidance discusses the calculation of daily estimates
from annual estimates.

4.1 POINT SOURCES

4.1.1  Bulk Terminals  (Loading Racks)
    Calculation based on a device control efficiency and RE
    questionnaire results.

    A petroleum products bulk terminal distributes motor gasoline
and distillate fuels (heating oils, etc.).  In 1990, the facility
distributed 110,000,000 gallons of gasoline and 54,000,000
gallons of distillate fuels.  The loading racks used to transfer ,
the fuels use refrigerated vapor recovery units (RVUs) to control
emissions.  The control efficiency for RVUs is greater than 90
percent as determined by an approved EPA method.  The equipment
is checked annually unless obvious problems require earlier
inspections, and records of all repairs are maintained for agency
review.  The facility is inspected triennially, with the most
recent inspection occurring 3 years ago.  Emission factors for
gasoline and distillate fuel loading loss have been determined to
be 8.5 and 0.02 pounds VOC per thousand gallons, respectively.  A
questionnaire was completed for this facility and a RE of 78
percent was estimated for this facility (overall 82 percent for
the category).  What emissions should be reported for this
facility?

Answer: Compute the loading losses for gasoline and distillate.
        Emissions are based on emission factors and therefore
        must include RE.  Use the facility-specific RE rather
        than the category estimate.

                  Base Data  for Loading Losses
Gasoline Distillate
Throughput
(gallons)
Emission Factor
Control Efficiency
(AP-42)
Rule Effectiveness
110,000,000
8.5 Ibs VOC/103 gal
>90%
78%
54,000,000
0.02 Ibs VOC/103 gal
>90%
78%
                                36

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               Emissions = Emission Factor  Activity Level
                         x (1 - (Control Efficiency x RE))
    A.   Gasoline Loading Losses

     Emissions - 8.5 Ibs VOC/1Q3 gal x 110,000,000 gal x (1 - (0.90 x 0.78))
              = 278,630 Ibs VOC


    B.   Distillate Fuel Loading Losses

     Emissions = 0.02 Ibs VOC/103 gal x 54,000,000 gal x (1 - (0.90 x 0.78))
              = 321.8 Ibs VOC


    C.   Total Emissions  (from Loading Losses)

         Total Emissions = Gasoline Emissions + Distillate Emissions
                      = 278,630 + 321.8 Ibs VOC
                      = 278,952 Ibs VOC
                      = 139  tons VOC
4.1.2  Beverage Can Coating
    Calculation based on an effective control efficiency in
    the  absence of a control device, solids equivalency
    determination and RE questionnaire results.

    A beverage can coater has been required to use high-solids
coatings for  its interior can coating.  The plant personnel
follow a weekly maintenance routine.  The facility was  last
inspected  in  June for compliance evaluation, with the last
previous inspection occurring three years ago.  The  following
coating  and process characteristics have been determined.

    The  coater previously used 50 gallons per day of interior can
coating.   The coating had a density of 9 pounds per  gallon.  The
coating was 60 percent solvent (by weight); the solvent was 100
percent VOC with a density of 8 pounds per gallon.   The coater is
required to use a new coating that does not exceed 3 pounds of
VOC per gallon of coating.  The manufacturer reports a  density of
10 pounds  of  coating per gallon of reformulated coating.  No
change in  production volume of coated cans has occurred,  but the
coating consumption (in gallons per day)  is not reported in this
year's inventory.   This facility was not included among the
questionnaires,  but the category average RE is 84 percent.   What
emissions  should be reported in the inventory?

Answer:  In most categories,  control efficiencies and RE are
        applied to uncontrolled plant emissions resulting in RE
        emissions.   Since the end result of coating  is  the
        application of the solid fraction of the coating, control
        efficiencies for coatings are calculated as  the reduction
                                37

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          in emissions related to the  coating  solids only.   Thus,
          the first  step  in  estimating the control  efficiency  for
          this example is to estimate  VOC  emissions per volume  of
          solids.
Old Coating
  Solve/it Volume Fraction = Coating Density x
                                         Solvent Height Fraction
                                             Solvent Density
                         (9 Ibs of coating/gal coating) x (0.60 Ibs solvent/Ibs coating)
                                          8 Ibs solvent/gal coating
                       = 67.5%
          Solids Required = Coating Consumption x  (I - Solvent Volume Fraction)
                        = (50 gal coating/day) x (1 - 0.675)
                        = 16.25 gal solids/day
 Emissions * Coating Consumption x Solvent Volume Fraction x Solvent Density
            x Solvent VOC Fraction
          = 50 gal coating/day x 0.675 gal solvent/gal coating x 8 Ibs solvent/gal solvent
            x 1.00 Ibs VOC/Ibs solvent
          =270 Ibs VOC/day
                 Emissions per Volume Solid
   VOC Emissions
  Solids Required

=   270 Ibs VOC/day
  16.25 gal Solids/day

= 16.6 Ibs VOC/gal Solids
New Coating
                       „ ,             VOC Content of Coating
                Solvent Volume Content =	
                                         Solvent Density

                                     =  3 Ibs VOC/gal Coating
                                       8 Ibs VOC/gal Solvent

                                     = 0.375  gal Solvent/gal Coating
                                     = 37.5%
                                       38

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                 Solids Volume Content = 1 - Solvent Content of Coating
                                    = 1 - 0.375
                                    = 0.625 gal Solids/gal Coating
                                    - 62.5%
                   Coating Required
             Solids Required
          Solids Volume Concent

              16.25 gal Solids/day
          ^.625 gal Solids/gal Coating

          26.0 gal Coating/day
            Emissions = Coating Required  Solvent (VOC)  Content of Coating
                     = 26.0 gal Coating/day  3 Ibs VOC/gal Coating
                     =78.0 Ibs VOC/day
                 Emissions per Volume Solids
                    Emissions
                  Required Solids

                   78.0 Ibs VOC/day
                  16.25 gal Solids/day

                =4.80 Ibs VOC/gal Solids
Now that the emissions rates per gallon of  solids have been
determined,  the  control  efficiency  and  emissions  may  be
determined.
   Control Efficiency - (1 -
 Controlled (New Coating) Emissions per Volume of Solids
Uncontrolled (Old Coating) Emissions per Volume of Solids
                          4.80 Ibs VOC/gal Solids
                          16.6 Ibs VOC/gal Solids
                     71.1%
     Emissions = Solids Required x Uncontrolled VOC/gal Solids x
                     (1 - (Control Efficiency x RE) )

              = 16.25 gal Solids/day x 16.6 Ibs VOC/gal Solids x {1-  (0.711 x 0.84))

              = 109 Ibs VOC/day

          (This  is an  illustrative case.   In an actual
          inventory, emissions from  the exterior coating
          would  also be calculated.)
                                       39

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4.1.3  Paper Coating Facility
     Calculation based on direct determination of emissions.

     A paper  coater uses only coatings specified by the
manufacturer to contain 2.9 pounds VOC per gallons, less water,
to comply  with the RACT limit.   Coating usage at the plant is
documented to be 100 gallons,  less water,  per day and no
additional solvents are used.   This information was confirmed
during the annual inspection.   The RE for this source category
has  been determined to be 70 percent based on the RACT reduction
calculated for the category.  What emissions should be reported
in the inventory?

Answer: Emissions from this plant can be calculated by means of a
        direct determination, because the solvent concentration
        is determined based on  the manufacturer's specification
        and  the coating use is  documented daily, thus RE does not
        need to be applied.

                                                  »              ._
     Emissions = VOC content of coating x Coating usage

            = 2.9 Ibs VQC/gal coating less water x 100 gal coating less water/day

            =290 Ibs VOC/day
4.1.4  Metal Furniture  Coating
    Calculation based on  transfer and control efficiencies
    and the default  RE  value.

    A large metal  furniture  manufacturer applied 326 gallons of
coating solids on  its furniture each day (i.e.,  it actually
sprays more, but only 326 gallons of solids  are  actually
deposited    the products).   The coating it  uses contains 35
percent by volume  solids  (65 percent VOC).   The  solvent used
weighs 7.33 pounds per  gallon.   The  facility uses high-volume,
low-pressure  (HVLP)  spray equipment  to achieve an 85 percent
transfer efficiency  (TE).  The  facility has  also installed RACT
to achieve an estimated 82 percent emissions reduction.  The
default RE has been  applied  to  this  source category (80 percent)
What emissions should be  reported in the inventory?

Answer: Uncontrolled emissions  should be determined by
        calculating  the amount  of coating solids applied and the
        amount of  coating applied.   Controlled emissions are
        based on the RACT emissions  reduction and the default RE.
                                40

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               ,   ,,_,      _,  326 ?ai solids/day
           Total solids sprayed =	 = 384 gal solids/day
                                  0.85 TE
                            gal solids/day
         Total coating applied =
                     384 gal sol ids/day
                              % solids     0.35 gal solids/gal coating


                          = 1,096 gal coating/day
                   ,,_,„,  .
             Uncontrolled Emissions
            coating           Ibs VOC
                   x % solvent x ..
                             gal VOC
                                    day
     Uncontrolled Emissions = (1,096 gal coating/day) (0.65)  (7.33 Ifcs VOC/gal VOC)

                      "= 5,227 Jis VOC/day
         Emissions = Uncontrolled Emissions x Ci - (Control Efficiency x RE))

                       Ibs VOC
                 = 5,227 	 x (1 - (0.82) (0.80))
                  1,798
  day


Ibs VOC

  day
4.1.5   Automobile Assembly Plant:
     Calculation based on a device control efficiency, and
     solvent-use recordkeeping and RE questionnaire results.

     An  assembly plant that coats  automobile parts uses 150
gallons per day of  coatings containing 5.5 pounds VOC per gallon.
An additional 10 gallons of solvent,  with a density of 7.1 pounds
VOC  per gallon, is  used for cleanup each day.   Emissions are
controlled by a carbon adsorber that demonstrated a 90 percent
capture and control efficiency during a recent  test.  The plant
keeps substantial records of coating and solvent  usage, but no
data on control device operation  and/or maintenance (O&M).  The
RE for  this source  category has been determined to be 75 percent
based on questionnaire responses.   What emissions should be
reported in the inventory?

Answer:  It may appear that emissions can be calculated by means
         of a direct determination due to the good coating and
         solvent records at the source.  However,  the presence of
                                  41

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         a control  device precludes direct determination of
         emissions.   Therefore/ RE needs  to be included in the
         emissions  calculation.
      Uncontrolled Emissions = {150 gal Coating/day x 5.5 Ibs VOC/gal Coating)

                           +  (10 gal Solvent/ day x 7.1 Ibs VOC/gal Solvent)

                        = 825  Ibs VOC/day + 71 Ibs VOC/day

                        = 896  Ibs VOC/day
         Emissions = Uncontrolled Emissions x (I - (Control Efficiency x RE) )

                 = 896 Ibs VOC/day x (1 - (0.90) (0.75) )

                 = 291 Ibs VOC/day                       ,
4.1.6   Large Appliance Coating
     Calculation based on an irreversible process change  and
     direct determination of emissions.

     An  appliance manufacturer uses 1,200 pounds of a powder
coating per day.  The coating is applied with electrostatic spray
equipment achieving  a transfer efficiency of 95 percent.   The
company also uses 10  gallons of solvent  with a density of
7.1  pounds VOC per gallon solvent for daily cleanup operations.
The  plant keeps detailed records of coating and solvent  use.   The
RE for  this source category has been determined to be 75 percent.
What emissions should be reported in the inventory?

Answer:  Powder coating is an irreversible process change,  but the
         cleanup solvent emissions must be calculated.7 Since
         there are no  controls for the cleanup solvent, but
         adequate records are kept, a direct determination  of
         emissions can be made:
                   Emissions = (7.1 Ibs VOC/gal x 10 gal/day)

                           =71 Ibs VOC/day
 Powder coating may not always be an irreversible change;  the state or local
agency should make this determination.

                                  42

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4.1.7   Large Petroleum Dry Cleaner
     Calculation based on the expected rule control
     efficiency, reported controlled emission and the default
     RE value.

     A  large petroleum dry cleaner has  an  estimated controlled
emission  rate of 200 tons of VOC per year.   The RACT control
level  is  80 percent based on analysis  of  the rule for the
nonattainment area.  The plant is in operation 310 days per year,
All  inventory categories have been  assigned the 80 percent
default RZ  value.  What emissions should  be reported in the
inventory?

Answer:   Emissions should be calculated as  follows:

                                   Controlled Emissions
                Uncontrolled Emissions =
                                   (1-Control Efficiency)
                                   200 tons VOC/year

                                      (1-0.8)

                                 = 1,000 tons VOC/year
      Daily Emissions = Uncontrolled emissions x (1 - (Control Efficiency x RE))


                    1,000 tons VOC/yr x 2,000 Ibs/ton
                            310 days/yr

                  - 2,322 IBS VOC/day
                                             x (1 - (0.80)(0.80))
4.1.8     Graphic Arts
    Calculation based on multiple sources at  one  facility,
    with  and without controls.

    A printing manufacturer uses two gravure  lines  at a given
facility.   The first gravure line (line 1) was  uncontrolled in
1990 and  did not comply with SIP rules at that  time;  the second
gravure line was controlled by a fume incinerator meeting the
State SIP rule.   (Line 1 was subsequently upgraded  in 1991  to
include fume incineration).  Plant personnel  are  required to
complete  a  formal training program on operation and maintenance
and follow  maintenance guidelines daily.  The facility was  found
out of compliance during the past year due to incineration
failure but  was  back in compliance within 72  hours.   A violation
notice was  placed into the State Agency files.  The facility is
inspected annually.   The device control efficiency  for fume
incineration was determined to be 95 percent  during the previous
compliance  test.  Following a survey using the  questionnaire,  RE
for graphic  arts was calculated to be 85 percent.
                                 43

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    For line process, 25,000.pounds of  ink (12 percent VOC by
weight)  were used.   Other solvents used for viscosity adjustment
and cleaning totalled 100/000 pounds  (100 percent VOC).  A total
of 900,000 pounds  of ink  (60  percent VOC by weight)  were used  in
line  2,  while  600,000 pounds  of other materials  (100 percent of
VOC)  were used for Line 2.  The ink consumption  is  tracked daily
at the  press and the VOC  content is given by the manufacturer.
What  are the annual emissions from this facility with Rule
Effectiveness?

Answer:  The two  gravure lines must be treated separately.  Line 1
         had no controls and RE zero because there was no attempt
         at compliance.  The second gravure process  (Line 2)  is
         controlled and RE must be applied.   For comparison,
         facility emissions with and without RE are  presented.

         A.  Line 1  Gravure Process (No  Controls)

                  Emissions = Ink Emissions •»• Other Emissions
                                                      *                _
             1.   Ink Emissions:

               Ink Emissions =  Ink Consumed x Ink VOC Fraction
                          =  25,000 Ibs Ink x 0.12 Ibs VOC/lbs ink
                          =  3,000 Ibs VOC
             2.  Emissions for  Other Solvents:

  Other Solvent Emissions = Other Solvents Consumed x Other Solvent VOC Fraction
                     = 100,000 Ibs Other Solvents x 1.00 Ibs VOC/lbs Other Solvents
                     = 100,000 Ibs VOC
             3.  Line  1 Emissions:

               Emissions = Ink Emissions + Other Solvent Emissions
                       = 3,000 Ibs VOC + 100,000 Ibs VOC
                       = 103,000 Ibs VOC
                       =51.5 cons 700
         B.   Line 2  Gravure Process
                 Step 1 - Before Rule Effectiveness

    Emissions = (Ink Emissions + Other Solvent Emissions) x (1 - Control Efficiency)


             1.   Ink Emissions:

              Ink Emissions = Ink Consumed x Ink VOC Fraction
                         = 900,000 Ibs Ink x  0.60 Ibs VOC/lbs Ink
                         = 540,000 Ibs VOC
                                  44

-------
              2.   Emissions  from Other  Solvents:

     Other Solvent Emissions - Other Solvents Consumed x Other Solvent VOC Fraction
                        = 600,000 Ibs Solvent x 1.00 Ibs VOC/Ibs Other Solvents
                        = 600,000 Ibs VOC
              3.   Line 2 Emissions  (Before Rule Effectiveness)

    Emissions = {Ink Emissions + Other Solvent Emissions)  x (1 - Control Efficiency)
            = (540,000 Ibs VOC + 600,000 Ibs VOC) x (1 - 0.95)
            = 57,000 Ibs VOC
            =28.5 tons VOC
             Gravure Process  (Emissions Accounting  for RE)

        RE Emissions = (Ink Emissions + Other Solvent Emissions) x
                    (1 - (Control Efficiency x RE) )
                  = (540,000 Ibs VOC + 600,000  Ibs VOC) x (1 - (0-. 95 x 0.85) )
                  = 219,450 Ibs VOC
                  = 109.7 tons VOC
         C.  Facility Emissions

             Facility Emissions = Line 1 Emissions * Line 2 RE Emissions
                            =51.5 + 109.7 tons VOC
                            * 161.2 tons VOC
4.2 AREA SOURCES

4.2.1   Stage I  (Area Source  Category)
    Calculation based on rule penetration  and SSCD  study
    results.

    The gasoline  throughput  for service  stations in a
nonattainment area is reported to be 400,000 gallons gasoline per
day.   The uncontrolled Stage I emissions are estimated to be 11.5
pounds VOC per 1,000 gallons.   The State regulation requires 95
percent control at each facility and covers  about 90 percent of
the overall emissions from the category  (i.e.,  rule penetration  =
90 percent).  The RE for this  category has been determined to be
60 percent following an SSCD study conducted by the State agency.
What emissions should be reported .in the inventory?

Answer: RE and penetration should be introduced into the
         emissions calculation  as follows:
                                  45

-------
   Uncontrolled emissions = 400,000 gal gasoline/day x 11.5 Ibs VOC/l, 000 -gal gasoline

                    = 4,600 Ibs VOC/day
 RE Emissions = Uncontrolled emissions x (1 - (Control Efficiency x RE x Rule Penetration) )

           = 4,600 Ibs VOC/day x (1 - (0.95)(O.SO)(0.90))

           = 2,240 Ibs VOC/day


4.2.2  Architectural Coating  (Area Source  Category)
    Calculation based on  direct determination of emissions.

    The  ozone nonattainment area  inventory includes architectural
surface  coating as an area source category.   Architectural
coatings include surface  coating, painting and decorating of
architectural structures  using water-based and oil-based
coatings, cleanup solvents and thinners.   The agency describes  _
the following inventory method and emissions  data for the
category.

    Architectural surface coating use  (consumption) in the
nonattainment area is based on a comprehensive survey of all
coating  manufacturers and marketers in  the nonattainment area.
The survey  results provided consumption of each type of
coating/solvent/thinner and the manufacturers'  statement of its
solvent  content.   The survey results are- from 1990 and include
all coatings,  thinners and solvents used in the category.
Results  are an annual weighted composite VOC  emission expressed
as pounds VOC per gallon  coating  (0.46  pounds VOC per gallon) and
an estimate of 1,555,322  gallons of coating used in the
nonattainment area.  What emissions should be reported in the
base year inventory and what RE value should  be applied?

Answer:  Although applied  to an area source category,  this example
         follows the traditional point source  interpretation of
         direct determination because it provides (1)  an
         accounting of consumption and  (2)  use of a known solvent
         content.   However, the inventory procedures are entirely
         different for area source categories.  In this example/ a
         direct determination is based on the  mass balance done
         for the nonattainment area.


                Emissions * (0.46 Ibs VOC/gal) x  (1,555,322 gal)

                       = 715,448 Ibs VOC/year

                       =358 tons VOC/year
                                 46

-------

-------
           APPENDIX A

RULE EFFECTIVENESS QUESTIONNAIRE
          POINT SOURCES

-------

-------
                RULE EFFECTIVENESS EVALUATION FORM
                           Point Sources
    Source Category
    Source Name  	
    Source Location 	
    Source Identifier
    Choose  the one most  appropriate response  for each question.
Answers should be confirmed by information  in  the State or  local
agency's files.   When  the questionnaire has been completed,  tocal
the scores  to  determine RE for the  source;  the average score  for
all evaluated  sources  in  a category is the RE for that category.

Preliminary Screening:

1.  Is this source  currently  uncontrolled?              	
                                                     	 No
                                                     	 Yes
(If "yes" t choose another source to evaluate,  and indicate a RE
of 0 percent  for this  source in the inventory.)   '

Are emissions  from this  source controlled           	 No
by an irreversible process  change?                  	 Yes
(If "yes", choose another source to evaluate,  and indicate a RE
of 100 percent  for this  source in the inventory.)
    Have emissions  from this  source been.
    calculated by means of  a  direct determination?
                                                            No
                                                           "Yes
     '.If  "yes",  choose  another source to evaluate, do not apply  RE
    to  this  source,  and  indicate  a  RE  of 100  percent  in the
    inventory.) l
    Nature of the Regulation

    1.  Does the regulation contain uncorrected deficiencies  (not
        including record keeping deficiency)  as  specified in  the
        SIP-call  follow-up  letter  from  the  EPA  Regional   Air
        Division Director  to your State Air Program Director?
            No               (5:
            Yes or unsure    (0}
                                                 Score
    If a source's emissions have been estimated using direct determination, maintain the supporting data and
    calculations in your files.

                                A-2

-------
        Does the State require source to keep records sufficient to
        enable an inspector to determine compliance  status?
            Yes
            No or unsure
                                                    0)
                                                     Score
        How complex is the determination of compliance?  (If  State
        can  verify through  detailed records  that  all necessary-
        compliance determination procedures have been carried out,
        score  5 points  for this  question regardless  of answer
        checked below.)
            Determination can be made by looking at
            facility, as in the case of an equipment
            standard.
            Determination can be made by collecting
            and analyzing one sample or by evaluating
            continuous emission monitoring reports.
            Stack testing,  including capture and *
            control, must be performed to determine
            compliance.
            Determination requires that multiple
            samples be taken and analyzed and that
            plant records be evaluated, as in the case
            of cross-line averaging, time averaging,
            or other bubbles.
                                                    Score
                                                   (2
B.  Nature of Procedures__Used to Comply With Regulation

    1.  This question concerns the relative  level of confidence in
        the  long-term   performance   capabilities   intrinsic  to
        different control techniques  (e.g.,  how time in operation
        and  maintenance  degradation  might   affect   emissions
        control) .   (Check each  technique used at  the facility,
        total the scores assigned to each control,  divide by the
        number  of  controls  and  report the  average as  a single
        score.   If State can verify  through detailed records that
        zhe source has  actually  been in continuous compliance at
        all times during the past two years,  score  10 points on
        this question regardless of  control methods used.)
                                       [e.g.,  coating
Floating roof
Thermal incinerator
Vapor balance
Reversible process change
reformulation)
Condensation system
Carbon adsorber
Catalytic incinerator
Other (assign point value <_ 10, as
appropriate, relative to above controls!
(8)
(8)

(8)
(7)
(7)
(7)
                                                    Score
                               A-3

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     2.   Are fugitive emissions  that might  cause noncompliance a
         possibility  where  add-on controls are used  (cheese one)?

      . 	    No or not applicable because
             there is no add-on  equipment                        (5)
     	    No, because they  have been shown by
             an EPA-approved capture efficiency
             test to  be below  allowable limits and
             to be so on a  continual basis                       (5)
     	    Yes or unsure                                        (0)
                                                       Score   	
C.   Performance of Source  in .'.''jprnplying. With .Regulation
     1.   What procedures  dc-:-1
         maintenance  (O&M)  .i
•rhe  source follow  for  operation and
che control equipment (check one)?
             Plant personnel  complete a formal
             training program and follow daily
             written instructions for O&M
             Same as above, except  no training
             Plant personnel  follow weekly
             established OiM  routine
             Equipment is assumed to be operating
             correctly unless  major malfunction
             is detected
                                   (5:
                                   (4!

                                   (3


                                   (i:
                                                       Score
         What is the nature of self-monitoring efforts  conducted by
         the plant to assess  compliance (check one}?
             Source test  (using  EPA-approved
             method) -1  is conducted annually
             Sample analysis  (using  EPA-approved
             method) -'  is conducted for each  ink
             or coating used
             Above tests are performed,  but
             less frequently
             None or unsure
                                   ;3
                                   ;o
                                                      Score
        Does  the  plant  keep  records  of  data  (including  self-
        monitoring,   O&M,  coating  usage,  etc.!  that  would  allow
        verification of compliance?
             Yes .
             No or unsure
                                                      Score
   ^or examples of approved test methods, see "Test Methods or Procedures for Group I, II, and III CTG's," Issues
Relating to VQC Regulations. Cutpoims. Deficicndi's. and Deviations. EPA/OAQPS/AQMD/OCMPB/PIS, May 25,
1988.


   •'Ibid.
                                A-4

-------
    4a. Has source been found to be out of compliance  in  the  last
        12 months?  (If "yes",  then answer question  4b;  otherwise,
        skip to Part D)
          No
          Yes or unsure
                                                       (0)
                                                    Score
    4b. In  responding to  Notices  of  Violation,  did  the source
        demonstrate  compliance  within  the  required  time frame?
        (Answer  this  question  only  if  you  answered  "yes"   to
        question 4a. above)
          Yes
          No or unsure
                                                       5
                                                       0
                                                    Score
D .   Performance of Implementing Agency in Enforcing Regulation

    1.  Please   answer   the   following   questions   regarding
        verification of the source's compliance? .,
a.
        c.
            Are all permits and abatement orders
            available?                       •         _ No  (0)
                                   _ Yes or not applicable  (2)
                                                    Score _
            Are all applicable requirements identified
            in the permit (e.g.,  emission limits,
            averaging times, compliance schedule,
            monitoring,  recordkeeping, reporting,
            operation and maintenance, test
            requirements)?
                                              	 No (0)
                                Yes or not applicable (2)
                                            Score 	
    Are accurate and complete flow diagrams
    available for the emission points and
    control,  capture, ventilation and process
    systems?                        .           _^	 No (0
                           	 Yes or not applicable (2
                                            Score 	
            Are all source test and sample analysis
            results available?
                                                   No (0)
                                        Yes or not applicable  (2)
                                                    Score
            Are all appropriate control system
            operating data available?                     	 No
                                   	 Yes or not applicable (2)
                                                    Score 	

                                              Total Score 	'
                               A-5

-------
2 .  What is the professional background of the person who most
    frequently  inspects 'this  source?    (Choose  the one most
    applicable answer  with highest  score.)

	  Has >_ 3  years  of  experience  in
      conducting  plant  inspections                         (5)
	  Has engineering degree  and has completed
      formal  training program on how to
      conduct  plant  inspections                            (4)
	  Has engineering degree                                (3)
	  Has completed  formal training  program
      on how to conduct plant inspections                   (3)
	  No training, < 3  years  of experience,
      and no  engineering degree                            (0)
	  Unsure                                                (0)
                                                Score 	
3 .  How many  times has source been  inspected  in the past 24
    months?    (Inspections  must  be  confirmed  by inspection
    reports in  implementing Agency's file.}

	  >2 times,  unannounced                   ,            (10)
	  Once  or  twice,  unannounced                            (8)
	  Once  or  more, with prior  notice or  unknown
      if notice  given                                      (6)
	  None  or  unsure                                        (0)
                                                 Score 	
4.  What was the highest level of inspection performed at the
    source in the- last 24 months?   (This must be confirmed by
    inspection reports in the implementing agency's file.)

	 Level 4:  sampling  inspection  including
     preplanned  sample collection                         (5)
	 Level 3:  compliance evaluation                      (4)
	 Level 2:  walk-through                               (2)
	 Level 1:  observation from outside                   (1)
	 None or unsure                                       (0)
                                                Score 	
5.  Does  the agency  generally  determine  compliance  by the
    method(s) specified in the regulation?

	 Yes                                                   (5)
	 No or unsure                                          (0)
                                                Score 	
6.  If this source has been found out  of  compliance within the
    last 12 months,  has  formal documented enforcement action
    (e.g.,    consent   decrees,   variances,   court   actions,
    penalties) been taken against the source?

	 Not applicable because  source has not'
     been  found  out of compliance                         (5)
	 Yes                                                  (5)
	 No or unsure                                         (0)
                                                Score 	
                           A-6

-------
    7.  If source has been found out of compliance within the last
        12 months, has a follow up inspection been made to affirm
        compliance?
            Not applicable because source has not
            been . found out of compliance
            Yes
            No or unsure
                                               5)
                                               0)
                                                    Score
SCORING:

A: 	 of 15

TOTAL SCORE  =
B:
of 15
C:
of 25
D:
Of "45
       of  100 points maximum = RE value for source
                               A-7

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           APPENDIX B

RULE EFFECTIVENESS QUESTIONNAIRE
     AREA SOURCE CATEGORIES

-------

-------
                RULE EFFECTIVENESS EVALUATION FORM
                      Area Source Categories
    Source Category
    Location 	
    Choose the one.most appropriate response for each question.
Answers should be  confirmed by information in the State or  local
agency's files.  When the questionnaire has been completed, total
the scores to determine RE for the category.
1.
Does the regulation contain uncorrected deficiencies as
specified in the SIP-call follow-up letter from the EPA
Regional Air Division Director to the State Air Program
Director?
          No
          Yes or unsure
                                                           (5)
                                                           (0)
                                                     Score
2.
What has been the nature and extent of source education on
requirements of the regulation?   (Check all that apply and
sum scores.)
           Individual  source mailings on compliance
           requirements                                         (7)
           Educational opportunities for
           plant personnel                                      (7)
           General notices in newspapers, trade
           journals, etc.                                       (3)
           Inform trade association                             (3)
           None                                                 (0)
                                                     Score
3.   What percentage of sources in the inventory typically are
    spot checked annually  (c-hecJc one) ?

    	 >30 percent                                          (20)
    	 10-30 percent                                        (15)
    	 5-9 percent                                          (10)
    	 1-4 percent                                           (5)
    	 <1 percent or don't know                              (0)
                                                     Score
                               B-2

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What percentage  of the  past  year's  spot  checks indicated
compliance  (check one) ?

	 100 percent
	 90-99 percent
	 50-89 percent
	 25-49 percent
	 1-24 percent
	 <1 percent  or don't know
	 Not applicable since no spot checks
       were  done
                                                  Score
                           (30)
                           (25).
                           (20)
                           (10)
                            (5)
                            (0)

                            (0)
Has formal documented enforcement  action been  taken  against
sources found to be out of  compliance  (check one) ?
     Not applicable since no  inspected
       sources  have  been found to be out
       of compliance
     Yes, for  all noncomplying
       sources
     Yes/ in 50 to  99 percent  of the cases
     Yes/ in < 50 percent of  the cases
     Never/ or don't know
                           (10)

                           (10)
                            (5)
                            (2)
                            (0)
                                                  Score
Have enforcement actions for sources in this  source  category
been publicized in the media  (newspaper, TV,  radio,  trade
journals)/ either through news stories or paid advertisements
(check one) ?
     Not applicable since no inspected sources
      have been  found  to be  out  of  compliance
     Yes, in every case
     Yes, in 50 to 99 percent of the cases
     Yes, in < 50 percent of the cases
     Never, or don't know
                            (5)
                            (5)
                            (3)
                            (1)
                            (0)
                                                  Score
Have follow-up inspections been made on sources which  were
found to be out of compliance  (check one) ?
     Not applicable since no inspected sources
      have been  found to be  out  of  compliance
     Yes, in 100 percent of the  cases
     Yes, in 50 to 99 percent of the cases
     Yes, in < 50 percent of the cases
     Never, or don't know
                           (10)
                           (10)
                            (5)
                            (2)
                            (0)
                                                 Score
        TOTAL SCORE: 	
        (100 points maximum)
= RE for Area Source Category
                           B-3

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         APPENDIX C




DIRECT DETERMINATION EXAMPLE

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                   DIRECT DETERMINATION EXAMPLE
    The following wood furniture coating scenario illustrates
typical emission inventory information that may be collected in
the surface coating category.   This type of information is used
to'make and support a direct determination of emissions for an
ozone base year SIP inventory.
FACILITY:
DESCRIPTION
RITEWAY FURNITURE
100 Commerce Drive
Ozoneville, USA
    Riteway Furniture fabricates arid paints oak furniture.  The
plant uses high VOC stains, lacquers, glazes and sealers.  This
source is covered under the State's applicable RACT rules for
wood furniture surface coating.  Some of their lines have already
been converted to high volume, low pressure (HVLP*) spray guns. ~
On average, their coatings range from 5.67 Ibs VOC/gallon coating
to 6.2 Ibs VOC/gallon coating.  The State air agency has
recommended that other lines be converted to HVLP spray guns and
that average coating solvent content be capped at 6.0 Ibs VOC
(monthly average) for their forthcoming permit amendment.
EMISSION SOURCES

    POINT
    SB-1
    SB-2
    SB-3
    SB-4
    SB-5
ADDITIONAL INFORMATION
    PROCESS
    Paint Spray Booth
   1990
CONTROL DEVICE
    None
    None
    None
    None
    None
THROUGHPUT
(see attached
 sheets)
    The facility summarizes and submits monthly summary data to
the State.  Coating and solvent usage  (including thinners and
cleanup) are tracked as used at the booths, but the spray booths
are not counted separately.  The facility was inspected in 1990
and the monthly summaries were consistent with their daily
records on file at the plant, according to the State compliance
enforcement.
    The attached sheet is a monthly spreadsheet from Riteway; all
twelve are on file at the State agency.  The "LBS VOC/GAL" come
from manufacturer's specifications for the coatings.
                               C-2

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ANSWER: There is sufficient information for direct determination
        of emissions because the amount of each coating and
        thinner/cleanup solvent used is tracked and documented
        regularly for each coating/solvent/ the VOC content of
        these coatings has been provided by the manufacturer and
        the amount emitted is a mass balance calculation based on
        these data.  In this instance/ 100% emission has been
        assumed.  The facility would be expected to document any
        claims that less than 100% is emitted  (e.g., some VOC is
        incorporated into the product.)
                               C-3

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RITEWAY FURNITURE:  JANUARY 1990 EMISSION REPORT
MFC NUMBER
S3-4100
S7-4057
PSA7-2460
Pl-3262
PC3-888
PC7-935
PC8-870
LS-1582
LS-1728
PC-1006
T-636
WS-2196
WS5-3503
WS7-2S89
WS7-3303
WS7-3465
F-2679
CA-175
F-2554
F-2672
LE2-3229
07-1189
08-1190
PF7-2251
T-17Q3
T-1743
T-1665
T-1769
T-164B
T-1647
T-1529
T-1605
T-1S22
UV-505
DESCRIPTION
ENGLISH SAP STAIN
ANTIQUE ASH SAP STAIN
OAK/KORN IND.
WHITE PRIMER
ANTIQUE TONER
ENGLISH TONER
BLUE TONER
LACQUER SEALER
WASHCOAT
PENETRATING WOOD SEAL
MAX
CLEAR GLAZE
ASH WIPING STAIN
ANTIQUE GLAZE
OAK/KORN IND.
ENGLISH GLAZE
50 SHEEN CAT/LACQUER
CATALYST
60 SHEEN M/R LACQUER
60 SHEEN M/R LACQUER
WHITE LACQUER
E/G SHADE
BLUE SHADE
WATER BASE PUTTY
GLAZE REDUCER HYSOL 10
GLAZE REDUCER HYSOL 15
50/50 CUT HYSOL 10/15
MINERAL SPIRITS
LACQUER THINNER
WA5HOFF THINNER
LACQUER RETARDER
NCR STAIN REDUCER
VMSP NAPTHA
STRIPCOAT
A
LBS/
GAL
6.82
6.62
7.35
8.26
6.83
6. 93
7.73
.7.38
7.10
7.10
6.81
7.62
7.58
8.74
8.92
8.57
7.86
8.24
7,54
7.92
8.27
7.04
7.10
11.98
7.27
7.42
7,35
6.42
6.63
6.61
7.91
6.63
6.23
7.81
B
LBS VOC/ GAL
(less water)
6.81
6.61
7.03
6.02
6.53
6.53
6.41
6.05
6.51
6.51
6.81 ,
4.28
4.98
3.88
3.64
3.98
5.39
4.12
5.88
5.16
5.82
6.81
6.61
0.00
7.27
7.42
7.35
6.42
6.63
6.61
7.91
6.63
6.23
5.69
C
GAL
USED
0.00
56.00
0.00
190.0
0
90.00
10.00
65.00
92.00
30.00
0.00
0,00
20.00
15.00
55.00
S.OO
25.00
0.00
0.00
0.00
320.0
0
35.00
0.00
11.00
6.00
0.00
0.00
130.0
0
0.00
105.0
0

15.00

SS.OO

1,330
B*C
LBS VOC
EMITTED
0
370
0
1,144
588
65
417
557
19S
0
0
86
75
213
18
100
0
0
0
1,651
204
0
73
0
0
0
956
0
696
0
119
0
343
0
7,867
                      C-4

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ADDITIONAL QUESTIONS ON DIRECT DETERMINATION

Do the following examples constitute direct determination?

1.  The facility used the RACT level  (6.0 Ibs VOC) to calculate
    emissions.

    No, an assumed content cannot qualify as a direct
    determination.

2.  The facility used the RACT level to estimate one coating
    line.

    Four lines could be directly determined, but the single line
    could not be treated as a direct determination.

3.  The facility reported an annual mass balance, but daily
    records were not available during the inspection.

    The record unavailability would fail the reporting
    requirements for direct determination.

4.  The facility collected waste coating and shipped it offsite
    as hazardous waste.

    Yes, direct determination could be claimed if the manifests
    are on file and the solvent portion is quantified.  Yes, if
    this waste is not quantified, but no "credit" is given for
    the waste.  No, if this waste is not documented but is
    subtracted from the emissions.

5.  For the inventory year,  this source was not permitted under
    the regulation.

    This fact has no bearing on direct determination, only the
    application of Rule Effectiveness.

6.  The facility vents spray booth emissions to an incinerator
    and reports a 96 percent control efficiency and test report
    (the same mass balance documentation is submitted for
    uncontrolled emissions).

    With a control device, this calculation is no longer a direct
    determination and Rule Effectiveness must be applied.

7.  The facility reports that 2 Ibs VOC are consumed per 100
    pieces,  and submits monthly reports of production (pieces).

    Rate per unit of production is not suitable for direct
    determination where the production is not coating or solvent
    used.
                               C-5

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      APPENDIX D




DETERMINING SAMPLE SIZE

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-------
DETERMINATION OF  SAMPLE  SIZE

     The sample chosen for the RE questionnaire  survey  should  be
representative of the relevant category population  as a whole.
This means that the  size of the  sample must be statistically
adequate to represent that category population.  A  population
mean or proportion is estimated  by the corresponding mean  or
proportion of the sample.  In addition to the size  of the  sample
 (i.e./ the sources for which a questionnaire is  completed), it  is
also necessary to consider the makeup of the sample chosen.

     For many applications, the  population parameters  (i.e./.
population mean (i and population standard deviation o)  are
usually known or  can be  estimated.  In the case  of  RE,  estimating
these parameters  is  the  objective of the survey.  The population
mean can be approximated by the  sample mean with some degree of
error.  In deciding  on size of sample for a given survey/  several
elements must be  considered:

     The standard deviation of the population from*which the
     sample is to be drawn.  Lacking this information/  it  can be
     estimated either from past  surveys  (if available)  from the
     same population/ from an initial survey conducted  for this
     purpose  (the first  ten sources chosen at random) or from
     rational considerations of  what this population might look
     like.

     The degree of accuracy "e"  one would like to have  in the
     sample data.  This  is usually defined as an interval and is
     referred to  as  the  limit of error.  The sample mean will
     usually not  be  exactly equal to the population mean.  The
     size of this difference is  the limit of error  "e."

•    The degree of confidence o  one would like to have  to be
     confident that  the population mean is within the limit of
     error set above.

     Thus, if the sample mean is used as an estimate of the
population mean ji, we can be (1  - o)  x 100 percent confident that
the limit of error will be less than a specified amount "e" when
the sample size is at least
                                 1/2
where     n  =   sample size
          o  =   standard deviation of the population
          e  =   limit of error  (usually in the range of 5 to 10
                 percent of the value of the mean)
          a  =   confidence level
          Z
-------
                 a  (Percent)

                      90
                      95
                      99
                      99.7
1/2
1.65
1.96
2.58
3.00
     The following tables were developed using the equation
presented above.  They show the sensitivity of sample size with
respect to the confidence level a, the limit of error e, and the
standard deviation of the population from which the sample is to
be drawn.  There is a trade-off between confidence level and
limit of error.  The largest sample size provides the highest
confidence level and lowest limit of error.  In addition/ larger
sample sizes are required when the standard deviation is larger.
Conversely, the smallest sample size-provides the lowest
confidence level and the highest limit of error.  Smaller sample
sizes can be used when the standard deviation is lower.

     The following example illustrates the use of «the tables
presented above.  Assume that an air pollution control agency is
interested in estimating rule effectiveness (RE) in the can
coating industry.  However, no prior estimates on RE are
available from previous research.  Lacking such an estimate, the
initial survey was conducted on 10 facilities. •• Results of the
initial survey yielded an average RE value of 80 percent with a
standard deviation of   8 percent.  Assuming a 90 percent
confidence limit and a limit of error of 5 percent, the sample
size required is obtained from Table 1 and is equal to 7.  In
this case, the survey for this category would be complete.
However, if the standard deviation obtained from the initial
survey was   10 percent and the limit of error was 5 percent, the
number of facilities required for sampling increases from 7 to 11
facilities, and one more questionnaire would need to be
completed.  On the other hand, choosing a larger limit of error,
5.5 percent instead of 5 percent, will yield a sample size of 9
facilities instead of 11.

CHOICE OF SAMPLE SIZE

     For statistical purposes, the variables affecting the sample
size are the limit of error and the confidence level.  However,
decisions on actual sample size to be used must also include
considerations such as available resources and data quality
requirements.  A decision on what sample size to choose should
begin with an estimation of the resources necessary for execution
and data analysis.  The initial survey of ten randomly-selected
facilities can be used for that purpose.  The second step in
deciding on the size of the sample and the type of survey to be
conducted is to determine the resources available to the
surveying agency including staff time available for completing
the questionnaires.  The next step is to determine a sample size
                               D-3

-------
based on the statistical formulas and estimate the resources
required to conduct the survey.  Those resources are then
compared.to the resources available to the agency for the purpose
of conducting the survey.  If the resources needed exceed the
available resources, the agency should decide on an affordable
sample size.  This is achieved by modifying the acceptable limit
of error or confidence level or both.
     EPA recommends that the 90 percent confidence interval
(Table D-l) be used; the suggested sample error is 5 percent, but
should not exceed 10 percent.  State and local agencies are
permitted latitude to choose higher confidence intervals and
lower sampling errors.  Where these methods are used,  the SIP
documentation should state the selected error and confidence
levels.
                              D-4

-------
TABLE D-l.  SENSITIVITY ANALYSIS OF SAMPLE  SIZE:  CONFIDENCE LEVEL
90%

Sample
Error
2.5%
3.0%
3.5%
4.0%
4.5%
5.5%
6.0%
6.5%
7.0%
7.5%
8.0%
8.5%
9.0%

2%
2
1
1
1
1
0
0
0
0
0
0
0
0

4%
7
5
4
3
2
-A f''<' :.: :.•:. "v. ,ff '.
1
1
1
1
1
1
1
1

6%
16
11
8
6
5
3
3
2
2
2
2
1
1

8%
28
19
14
11
9
j.V.iJpl
6
5
4
4
3
3
2
2
Stan<
10%
44
30
22
17
13
9
8
6
6
5
4
4
3
dard Dei
12%
63
44
32
25
19
13
11
9
e
7
6
5
5
riation
14%
85
59
44
33
26
18
15
13
11
9
8
7
7

16%
112
77
57
44
34
fe 2 8 ":'
23
19
16
14
12
11
10
9

18%
141
98
72
55
44
29
25
21
18
16
14
12
' 11

20%
174
121
89
68
54
^:^:-m:;
36
30
26
22
19
17
15
13

22%
211
146
108
82

44
37
31
27
23
21
18
16

24%
251
174
128
98
77
52
44
37
32
28
25
22
19

-------
TABLE D-2.  SENSITIVITY ANALYSIS OF SAMPLE SIZE: CONFIDENCE LEVEL = 95%
Standard Deviation
Sample
Error
2.5%
3.0%
3.5%
4.0%
4.5%
5.5%
6.0%
6.5%
7.0%
7.5%
8.0%
8.5%
9.0%
2%
2
2
1
1
1
S:'4 irf
i
0
0
0
0
0
0
0 .
4%
10
7
5
4
3
2
2
1
1
1
1
1
1
6%
22
15
11
9
7
S- ••$..
5
4
3
3
2
2
2
2
8%
39
27
20
15
12
8
7
6
5
4
4
3
3
10%
61
43
31
24
19
13
11
9
8
7
6
5
5
12%
89
61
45
35
27
"'Ha*.!
18
15
13
11
10
9
8
7
14%
120
84
61
47
37
1" 30
25
21
18
15
13.
12
10
9
16%
157
109
80
61
49
33
27
23
20 .
17
15
14
12
18%
199
138
102
78
61
fl 59 ? •
41
35
29
25
22
19
17
15
20%
246
171
125
96
76
51
43
36
31
27
24
21
19
22%
297
207
152
116
92
61
52
44
38
33
29
26
23
24%
354
246
181
138
109
73
61
52
45
39
35
31
27

-------
TABLE D-3.  SENSITIVITY ANALYSIS OF SAMPLE SIZE:  CONFIDENCE  LEVEL
99%
Standard Deviation
Sample
Error
2.5%
3.0%
3.5%
4.0%
4.5%
5.5%
6.0%
6.5%
7 .0%
7.5%
8.0%
8.5%
9.0%
2%
4
3
2
2
1
ft|:y,"f :r] ;: y £:<:>.!, "•!£ •-£" '•:• :
, ::K^K: 1 &Y1*.": : *:: '. ", " ' :" - '
1
1
1
1
0
0
0
0
4%
17
12
9
7
5
4
3
3
2
2
2
1
1
6%
38
27
20
15
12
8
7
6
5
4
4
3
3
8%
68
47
35
27
21
14
12
10
9
8
7
6
5
10%
107
74
54
42
33
22
18
16
14
12
10
9
8
12%
153
107
78
60
47
32
27
23
20
17
15
13
12
14%
209
145
107
82
64
i!l'7':;£i:l
43
36
31
27
23
20
18
16
16%
273
189
139
107
84 _
56
47
40
35
30
27
24
21
18%
345
240
176
135
107
71
60
51
44
38
34
30
27
20%
426
296
217 .
166
131
88
74
63
54
47
42
37
33
22%
515
358
263
201

107
89
76
66
57
50
45
40
24%
613
426
313
240
189
:•:•:•:• *y :•:-£•••: . K-K-j/1-
153,
127
107
91
78
68
60
53
47

-------
                  APPENDIX E




DEFAULT CONTROL ASSUMPTIONS FOR CT6 CATEGORIES

-------

-------
The attached table lists the CTG categories and the approximate
control efficiency which the CTG authors identified .for the CTG
categories.  Many of the efficiencies depend on which control
method is used and the solvent content.  Closer analysis of the
CTG documents and references would likely improve the rough
estimates provided here.  EPA has not determined the validity or
reliability of this listing for the purposes of RE.
                               E-2

-------
     TABLE E-l.
TYPICAL VOC REDUCTION PER FACILITY  FOR CTG
CATEGORIES  BASED  ON CTG DOCUMENTS
            Category
             Low*  High*  Single
              (%)    (%)   Value
                     Comment
Point Source Categories
Gasoline Loading Terminals
Bulk Gasoline Plants
   Alternative 1
     Total Plant
     All Transfers
   Alternative 2
     Total Plant
     All Transfers
   Alternative 3
     Total Plant
     All Transfers
Fixed Roof Petroleum  Tanks
Refinery Processes
   VPS
  .. WS
   PUT
Surface Coating

   Cans
   Metal Coils
   Fabric and Vinyl
   Paper Products
   Automobiles & Light Duty
Trucks
      Prime Coating
      Top Coating
      Final Repair Coating
   Metal Furniture
   Magnetic Wire
   Large Appliances	
             60
             70
             80
             80


             80
             75
             NA
             50

             79
100
 98
100
 99


 93
 92

 99

 95
                              87
                             22
                             27

                             54
                             64

                             77
                             92
                             90+

                             100
                             95
                             98
                                 Solvent  %  and control
                                 dependent
90
                                (continued)
                                   E-3

-------
      TABLE E-l.
TYPICAL VOC REDUCTION  PER FACILITY FOR  CTG
CATEGORIES  BASED ON CTG DOCUMENTS  (continued)
            Category
             Low'  High*  Single
              (%)   (%)    Value
Conment
   Misc. Metal Parts
      Process Modification       50       98
      Exhaust Gas Treatment
   Flatwood Paneling             70       90
Graphic Arts
   Publication Rotogravure
   Packaging Rotogravure
   Flexographic Printing
Leaks from Petroleum Refineries
External Floating Roof Tanks      33       99
Gasoline Truck Leaks & Vapor      NA
Collection
Synthetic Pharmaceutical         NA
Manufacturing
Rubber Tire Manufacturing
   Carbon Adsorption             62       86
   Incineration                  59       81
   Water-based Coatings
Leaks from NG/Gasoline
Processing Plants
Mfg.  of HDPE,  PP, and PS Resins
SOC & Polymer Mfg.  Equipment
Fugitives
Large Petroleum Dry Cleaners      66       72
SOCMI Air Oxidation Processes
Thermal Oxidation
                            90+
                             75
                             65
                             60
                             62  Based  on  15,900 mVday
                             97
                             72 Model plants

                             98 Model Plants
                             36 under RACT
                             98 With controls above
                                baseline
                             53
                                (continued)
                                   E-4

-------
      TABLE  E-l.
TYPICAL VOC REDUCTION PER FACILITY FOR CTG
CATEGORIES  BASED  ON CTG  DOCUMENTS (continued)
            Category
             Low*  High*  Single
             (%)    (%)    Value
Comment
Area Sources
Service Stations - Stage I
Transfer Losses
Total Facility
Cutback Asphalt


95+
50
100
Solvent Metal Cleaning
   Cold Cleaning                 50      53
   Open-top Vapor Degreasing     45      60
   CD                           25      60
Perchloroethylene Dry Cleaners    40      70
                                +/- 20%
                                +/- 15%
                                +/- 10%
                                     *
                                Carbon  Adsorption
 Users  should  select  the  low value  from  a range unless  another  value is
 justified.   One-hundred percent  should never be used unless the emissions are
 directly determined or there has been an irreversible process  change.
                                   E-5

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-------